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Monday, October 27, 2025

Options Trader Alert #2025 - 48
Nasdaq ISE Proposal to List and Trade Certain Options on a Commodity-Based Trust Deemed Approved

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Effective Monday, October 27, 2025, Nasdaq ISE’s (ISE) rule proposal, SR-ISE-2025-08, is deemed approved.

On February 7, 2025, ISE filed with the Securities and Exchange Commission (“SEC”), a proposed rule change to amend its listing rules at ISE Options 4, Section 3 to allow the listing and trading of options on interests in a Commodity-Based Trust.  SR-ISE-2025-08 was published in the Federal Register on February 26, 2025. After designating a longer period to act, on May 3, 2025, the SEC issued an order instituting proceedings.  On August 15, 2025, the SEC designated October 24, 2025 as the date by which to issue an order approving or disapproving SR-ISE-2025-08.  On September 26, 2025, ISE filed an amendment to SR-ISE-2025-08. The SEC did not act to either approve or disapprove SR-ISE-2025-08, as amended, on or before October 24, 2025, therefore the proposal is deemed approved as of October 27, 2025.

As amended, Options 4, Section 3(h)(vi) specifies that ISE may list and trade interests in a Commodity-Based Trust that meet the generic criteria of The Nasdaq Stock Market LLC Rule 5711(d) provided the trust holds a single crypto asset.  Further, a Commodity-Based Trust that meets the requirements of Options 4, Section 3(h)(vi) must also satisfy the following requirements: (A) the total global supply of the underlying crypto asset held by the Commodity-Based Trust has an average daily market value of at least $700 million over the last 12 months; and (B) the crypto asset held by the Commodity-Based Trust underlies a derivatives contract that trades on a market with which the Exchange has a comprehensive surveillance sharing agreement, whether directly or through common membership in the Intermarket Surveillance Group.

For purposes of this rule the term “crypto asset” means an asset that is generated, issued and/or transferred using a blockchain or similar distributive ledger technology network including, but not limited to, assets known as “tokens,” “digital assets,” “virtual currencies,” and “coins” and that rely on cryptographic protocols. 

This proposal amends all 6 Nasdaq options market listing rules as Nasdaq’s affiliated options markets incorporate ISE Options 4, Section 3 by reference.


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