Exchange Offers Members Parent-Company Shares for Prepaid Fees
Published Date: 10/19/2026
Notice
Summary
24X National Exchange is tweaking its Warrant Performance Incentive Program, which lets members earn the chance to buy shares in its parent company by prepaying fees. These changes update how members qualify and earn rewards, aiming to keep things fair and motivating. The new rules kicked in right after filing on October 1, 2026, so members should check them out to stay in the game and maximize their benefits.
Analyzed Economic Effects
5 provisions identified: 4 benefits, 0 costs, 1 mixed.
New Lower $250K Prepayment Option
Members who join after the rule change may either prepay $500,000 to be eligible for both Original and Additional Equity, or prepay a reduced $250,000 to be eligible for Additional Equity only. The Prepayment Fee must be tendered by the first day of each quarter to participate as of that quarter, and no Member may become eligible for Original Equity after October 1, 2027; no Member may become a Participant after April 1, 2028.
Large Additional Equity Pool Added
Starting with trading in 2027, the Program makes 2,759,103 additional Non-Voting Common Units available for purchase (representing 22.25% of fully diluted units as of September 29, 2025). Those Additional Equity units are allocated across six Measurement Periods from January 1, 2027 through June 30, 2028, and the combined total available under the Program becomes 3,857,143 units (32.25%).
Additional Equity Vesting Based on Maker Volume
For Additional Equity only, Target Volume will be calculated based solely on Participants' maker volume (trades that add liquidity). Original Equity Target Volume continues to be calculated based on total trading volume. The Target Volume requirement remains 5% of the Exchange's average daily trading volume per Measurement Period as described in the Program.
Exchange Market-Share Threshold Removed
The Program removes the 24X Minimum Overall Market Share vesting requirement for both Original Equity and Additional Equity. After this change, vesting depends on Participants meeting the Target Volume without reference to a minimum 24X share of consolidated average daily volume.
Specific Index Rebalance Dates Excluded from Targets
The Exchange will exclude specific index rebalance and reconstitution dates (e.g., November 30, 2026; December 11, 2026; December 18, 2026; and a listed set of dates through June 23, 2028) from the calculation of Target Volume for both Original and Additional Equity. These dates historically concentrated auction volume on primary listing exchanges and would not count toward the Measurement Period Target Volume calculation.
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