MEMX Joins the Sponsored Access Rule Clarification Party
Published Date: 8/6/2025
Notice
Summary
MEMX is updating its rules to clearly define 'Sponsored Access' and require agreements between sponsors and participants to follow SEC’s Market Access Rule. This change affects anyone using sponsored access on MEMX and ensures safer, more responsible trading. The new rules kick in soon after a formal notice, with no extra fees announced.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Sponsored Participants Must Follow MAR
MEMX requires that the contract between a Sponsoring Member and a Sponsored Participant include a provision that the Sponsored Access relationship must follow the SEC’s Market Access Rule (SEC Rule 15c3-5, 17 CFR 240.15c3-5). Sponsored Participants will be contractually required to agree to follow the MAR, and Sponsoring Members are expected to amend existing contracts to add this provision.
Clear Definition of Sponsored Access
MEMX adds a formal definition of “Sponsored Access”: it means arrangements where a Member lets a Sponsored Participant send orders that bypass the Member’s trading system and are routed directly to MEMX, including through a service bureau or other third-party technology provider. The change makes clear which market-access relationships fall under Exchange Rule 11.3(a)-(b) and aligns MEMX’s wording with Cboe BZX and Nasdaq.
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