On September 23, 2025, Nasdaq PHLX LLC(“Phlx”或“Exchange”)向 Securities and Exchange Commission(“Commission”或“SEC”)提交了一项提案,依据 Section 19(b)(1) of the Securities Exchange Act of 1934(“Act”或“Exchange Act”)及其 Rule 19b-4 规定,拟上市并交易 Nasdaq Bitcoin Index options。As described more fully in the Notice,the Exchange proposes to list and trade options on the Nasdaq Bitcoin Index,an index that reflects the price of bitcoin。According to the Exchange,Nasdaq Bitcoin Index options will be based on the CME CF Bitcoin Real Time Index(“BRTI”)divided by a factor of 100,and the final settlement price for the options will be the CME CF Cryptocurrency Reference Rate—New York Variant(“BRRNY”)divided by 100,which will be known as the BRRNY—Nasdaq Options Settlement(“NOS”)。

Options on the Nasdaq Bitcoin Index will be cash-settled with European-style exercise. The Exchange states that holders of Nasdaq Bitcoin Index options will receive U.S. dollars representing the difference between the current bitcoin spot markets as represented by the BRRNY and the exercise price of the option.

The Exchange states that the proposal is designed to ensure that Nasdaq Bitcoin Index options are listed and traded under the same terms that apply to other index options traded on the Exchange. The Exchange states that its sales practice and trading rules, including rules addressing account opening, suitability, discretionary accounts, supervision of accounts, confirmations to customers, and delivery of the options disclosure document, will apply to the Nasdaq Bitcoin Index options. The Exchange states that it will apply the same surveillance procedures it applies to other index option products to the Nasdaq Bitcoin Index options.

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