MIAX Sapphire Tweaks Rule 527: Finance Wonks Rejoice
Published Date: 12/5/2025
Notice
Summary
MIAX Sapphire wants to update its rules to give members a one-time payment because of a system glitch on June 3, 2025, that caused problems. The SEC is now reviewing this change to decide if it’s fair and should be approved. This could affect members’ money and happens soon, with a decision expected by December 2, 2025.
Analyzed Economic Effects
5 provisions identified: 2 benefits, 3 costs, 0 mixed.
One-time cash payment to Members
MIAX Sapphire proposes a one-time cash payment to Exchange Members for validated losses from the June 3, 2025 operational error (trades canceled between 11:18 a.m. and 11:33 a.m. Eastern Time). The Exchange validated over 2,200 claims totaling approximately $500,000 and says it will implement payments if the SEC approves the rule change (decision expected by December 2, 2025).
Aggregate liability cap of $525,000
The Exchange proposes that its total liability for all claims arising from the June 3, 2025 Operational Error shall not exceed $525,000 for the single trading day (June 3, 2025) and the full calendar month of June 2025. The Exchange states it received and validated approximately $500,000 in claims and that only previously filed/validated claims will be eligible for distribution under this cap.
14-day attestation and release required
To receive a payment, Members must submit an attestation within 14 calendar days after the rule becomes effective that lists trade details (trade date, time, symbol, strike, expiration, side, quantity, venue, notional value, and claimed loss). Members must also execute and deliver a release of all claims (including affiliates) within 14 calendar days after the rule becomes effective; failure to provide the attestation or release voids eligibility.
Only previously filed, validated claims eligible
The proposed rule change states that only claims that were previously filed with and validated by the Exchange are eligible for payment; no new claims will be accepted. The Exchange reports it reviewed and validated over 2,200 claims related to the June 3, 2025 Operational Error.
Eligibility limited to canceled trades in set timeframe
Payments under the proposed rule apply solely to realized trading losses from executions that occurred on MIAX Sapphire on June 3, 2025 between 11:18 a.m. and 11:33 a.m. Eastern Time which were canceled and for which Members executed replacement trades on MIAX Sapphire or at away-exchanges. The measure of loss is the difference between the canceled trade execution price and the replacement trade execution price, as validated by the Exchange.
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