On 25 June 2025, the United States Commodity Futures Trading Commission (US CFTC) issued a No-Action Letter (CFTC No-Action Letter No. 25-17) in relation to MIAX Futures Exchange, LLC’s temporary trading of Minneapolis Hard Red Spring Wheat (HRSW) options on futures exclusively through block trades, administered by the Division of Market Oversight.
The No-Action Letter addresses MIAX Futures’ request to facilitate trading of HRSW options after the unavailability of an electronic trading system, following the migration of HRSW futures to MIAX’s Onyx platform on 29 June 2025. It provides temporary relief from certain Designated Contract Market (DCM) requirements under the United States Commodity Exchange Act, allowing market participants, including non-Eligible Contract Participants (non-ECPs), to trade out of or offset open positions in the September and December 2025 expirations. The relief is conditional, time-limited, and aims to ensure market continuity without compromising regulatory oversight.
MIAX Futures submitted the request on 23 June 2025, and the US CFTC issued the letter on 25 June 2025, with the relief effective from 29 June 2025 to 29 August 2025. The letter was open for public comment from 23 June to 25 June 2025.
The US CFTC has stated it will not recommend enforcement action against MIAX Futures for implementing the Temporary HRSW Options Block Trading Protocol, which permits block trades without a centralized market, lowers the block trade threshold from 15 contracts to one contract, and allows non-ECPs to participate, provided the following conditions are met: the relief applies only to HRSW options in the September and December 2025 expirations; MIAX Futures must promptly file and post rule amendments on its website; the amendments must be identified as temporary and tied to the no-action relief; MIAX Futures must respond to US CFTC requests for additional information; and MIAX Futures must provide advance notice of plans to enable electronic trading of HRSW options on Onyx. The letter specifies that MIAX Futures will monitor trading to prevent manipulation and price distortions, with its Market Regulation Department reviewing block trade prices for fairness using comparable trade data, settlement prices, and a proprietary options pricing application.
(Source: https://www.cftc.gov/PressRoom/PressReleases/9090-25)
