Pay Upfront, Trade Hard: New Warrant Incentive Program Launches
Published Date: 9/26/2025
Notice
Summary
24X National Exchange is launching a cool new Warrant Performance Incentive Program where members can prepay $500,000 in fees to earn the chance to buy shares in the parent company. To keep their rewards, members must hit certain trading volume goals during set periods. This program kicks off soon and offers a fresh way for active traders to benefit financially while boosting market action.
Analyzed Economic Effects
6 provisions identified: 2 benefits, 2 costs, 2 mixed.
Must Prepay $500,000 to Join
If you want to participate, you must prepay $500,000 in Exchange fees (the "Prepayment Fee"). The Exchange will apply that $500,000 to Program Exchange Fees on your invoice (connectivity, market data, membership and transaction fees, but excluding rebates and CAT fees); the prepayment does not expire and is applied until $500,000 of Program Exchange Fees are consumed.
Warrants Vest Only If Volume and Market Share Met
Participants receive warrants that only vest if (1) the Participant meets the Target Volume each Measurement Period (Target Volume = 5% of the Exchange's average daily trading volume for that Measurement Period) and (2) 24X meets the 24X Minimum Overall Market Share (0.50% CADV for each Measurement Period of Year 2 and 1.00% CADV for each Measurement Period of Year 3). The Program Period runs from September 29, 2025 through December 31, 2027 and Measurement Periods are defined by quarter (Year 1 is Sept 29–Dec 31, 2025).
Number of Units, Exercise Price, and Time Limits
A total of 1,098,040 Non-Voting Common Units (10% of fully diluted outstanding Units as of September 29, 2025) are available across the Program: Year 1 = 219,608 units (2%), Year 2 = 329,412 units (3%), Year 3 = 549,020 units (5%). Exercisable vested warrants allow purchase at $0.01 per Unit, and each vested warrant is exercisable from vesting until September 29, 2032 (the seventh anniversary of September 29, 2025).
Liquidity Program — Sellback at Discounted FMV
Beginning after January 1, 2029, Qualifying Participants (those who exercised warrants and hold Units) may sell portions of their Non-Voting Common Units back to 24X US Holdco on a schedule: for 2029 and 2030 up to 10% at 50% of Fair Market Value (FMV); 2031 up to 30% at 60% of FMV; 2032 up to 60% at 70% of FMV; 2033 up to 90% at 80% of FMV; 2034 up to 100% at 90% of FMV. In a Change of Control situation 24X US Holdco may purchase 100% at the applicable percentage (and after 2034 at 100% FMV).
Overnight Trading Gets 5X Credit but Is Capped
Trading during 24X Overnight Trading receives a 5X multiplier toward meeting Target Volume, but 24X Overnight Trading contributions are capped at 50% of the Target Volume (post-multiplier) for each Measurement Period. The 5X Overnight Multiplier applies from the date 24X Overnight Trading commences.
Strict Eligibility Rules — Broker-Dealers Only
Only 24X Members that are in good standing, registered broker-dealers under Section 15 of the Exchange Act, and qualify as accredited investors under Regulation D may join the Program. Applicants must also execute the subscription and confidentiality agreements and tender the Prepayment Fee by required deadlines (e.g., by September 26, 2025 to join at Program start).
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