SEC Clears Up 'Sponsored Access' in Trading Rules Update
Published Date: 8/6/2025
Notice
Summary
MX2 LLC is updating its rules to clearly define 'Sponsored Access' and make sure all agreements follow important SEC safety rules. This change affects members who let others trade through them and those who get sponsored access. The new rules kick in soon after a formal notice, helping keep trading safer without extra costs.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Formal Definition of Sponsored Access
The Exchange amends Rule 11.3(a) to add a definition of "Sponsored Access": an arrangement where a Member lets a Sponsored Participant send orders that bypass the Member's trading system and go directly to the Exchange, including via a service bureau or third-party provider. This makes clear which market access relationships are covered by Exchange Rules 11.3(a)-(b).
Contracts Must Cite SEC Market Access Rule
The Exchange adds Rule 11.3(b)(2)(J) requiring that the agreement between a Sponsoring Member and a Sponsored Participant include a provision that the Sponsored Access relationship must follow SEC Rule 15c3-5 (the Market Access Rule). Sponsored Participants must contractually agree to follow the Market Access Rule.
30-Day Operative Delay and Notice
The Exchange filed the rule change on July 28, 2025, and states the amendment will not become operative for 30 days after that filing date (i.e., operative after August 27, 2025) or on a shorter date if the Commission permits. The Exchange also will announce the exact implementation date via Regulatory Notice to existing and prospective Sponsoring Members and Sponsored Participants.
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