MIAX Emerald Bills Traders for Test Environment Access
Published Date: 5/15/2025
Notice
Summary
MIAX Emerald is starting to charge fees for traders and firms who want special access to their testing system, where they can try out new software and features before they go live. This change affects anyone using the dedicated connection to test trading tools and kicks in right away. If you want to test in this virtual playground, be ready to pay a fee starting now!
Analyzed Economic Effects
6 provisions identified: 3 benefits, 3 costs, 0 mixed.
$1,000/month Testing Connection Fee
MIAX Emerald now charges a monthly fee of $1,000 per dedicated cross connection (either 1Gb or 10Gb) to access its testing systems environment. This fee applies to both Members and non-Members and became effective with the filing on April 30, 2025.
Free VPN Still Available
MIAX Emerald continues to provide VPN access to its testing systems environment for free to all Members and non-Members. Firms may use the free VPN to perform the same testing functions without paying the $1,000/month dedicated connection fee.
Production Connections Decommissioned Feb 28, 2025
MIAX Emerald decommissioned access to the testing systems environment via 1Gb and 10Gb production connections on February 28, 2025, so affected firms had to switch to either VPN or a dedicated cross connection. The filing states that 37 firms needed to transition, with 6 choosing VPN, 9 choosing a 1Gb dedicated connection, 9 choosing a 10Gb dedicated connection, and 13 choosing not to maintain access.
Member-Initiated Certification May Trigger Fee
If a Member or non-Member initiates technology changes and must certify their systems, they will be subject to the Exchange's standard certification fee under Section 4 of the Fee Schedule. The filing distinguishes this circumstance from Exchange-initiated certifications, which are exempt from that fee.
Certification Fee Rule for Exchange-Initiated Changes
When certification is required because of an Exchange-initiated technology change, Members and non-Members may use VPN access for free and the Exchange's standard certification fee under Section 4 of the Fee Schedule will not apply. The filing notes this exception applies specifically to certifications due to Exchange-initiated changes.
No Latency or Trading Advantage for Paid Test Links
MIAX Emerald states that accessing the testing systems environment via a 1Gb or 10Gb dedicated cross connection provides no latency benefit or trading advantage compared to VPN access; the testing environment is for functionality testing only. Paying for a dedicated connection does not confer a performance edge in the test environment.
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