SEC

Securities and Exchange Commission (US)

High Impact

SEC Notice: Nasdaq MRX PMM Appointment Requirement Becomes Permissive for Options Classes

Published

Sep 15, 2026

Effective

Sep 2, 2026

Topics

Options market structure, Market maker appointments, Primary Market Makers, Competitive Market Makers, SRO rule change, Nasdaq MRX

Executive Summary

On September 15, 2026, the SEC published Nasdaq MRX’s immediately effective rule change amending MRX Options 2, Section 3(b). The amendment changes the appointment standard for Primary Market Makers from mandatory to permissive: a PMM may, rather than shall, be appointed to each options class traded on MRX. MRX states the change gives it class-by-class flexibility based on market conditions and the availability of qualified applicants. The filing does not change the substantive obligations or privileges of a PMM once appointed; appointed PMMs remain subject to MRX Options 2, Sections 3, 4 and 5, including opening-process valid-width quoting and the 90% intra-day two-sided quoting obligation described in the notice. Where no PMM is appointed, MRX says Competitive Market Makers can continue to provide liquidity under existing CMM obligations, including two-sided quotes in 60% of series in appointed classes. Business impact is limited: there is no new regulatory report, but market makers, routing desks and controls teams should update PMM coverage assumptions and monitor liquidity in classes without a PMM.

What Changed

modifiedPMM appointment standard

A Primary Market Maker shall be appointed to each options class traded on MRX.

New

A Primary Market Maker may be appointed to each options class traded on MRX.

modifiedExchange discretion by options class

The rule required a PMM appointment regardless of market conditions or applicant availability.

New

MRX may operate an options class without a PMM if appointment is not appropriate or viable.

modifiedLiquidity framework where no PMM is appointed

Each options class was expected to have a PMM appointment alongside other market makers.

New

Quoting and liquidity provision may proceed under the CMM framework without a PMM appointment.

modifiedPMM obligations unchanged when appointed

Appointed PMMs were subject to MRX Options 2, Sections 3, 4 and 5, including applicable quoting obligations.

New

Appointed PMMs remain subject to the same obligations, including the valid-width opening-process requirement and 90% two-sided intra-day quoting obligation described in the notice.

newImmediate effectiveness with delayed operability

New

Effective on filing on September 2, 2026; operative 30 days from filing unless shortened by the SEC.

Business Impact

Who is affected

Directly affected

Nasdaq MRX Members that seek or hold Primary Market Maker appointments, Competitive Market Makers appointed in MRX options classes, and exchange/venue operations teams.

Indirectly affected

broker-dealer routing desks, best-execution committees, market data/liquidity surveillance teams, vendors maintaining options venue reference data, and clients evaluating MRX liquidity.

Jurisdictions

United States - SEC-regulated national securities exchange options market

Business processes

PMM appointment application and renewal governance, Options class launch and market-maker coverage review, Market-maker quoting obligation surveillance, Best execution and smart order routing venue assessment, Venue reference data and liquidity monitoring

Estimated effort

Low

Compliance risk

Low

Affected Reports

PMM appointment inventory and options-class coverage controlOptions class launch or maintenance checklistMarket-maker quoting obligation surveillance configurationBest-execution venue liquidity review for MRX optionsSRO rule-change monitoring tracker for SR-MRX-2026-35

Field	Validation rule
MRX Options 2, Section 3(b) PMM appointment standard	Rule text changes from a mandatory 'shall be appointed' standard to a permissive 'may be appointed' standard for each MRX options class.
Options class PMM assignment status	An MRX options class may have no PMM appointment; in that case, liquidity provision proceeds under the CMM framework described in MRX Options 2, Sections 4 and 5.
PMM obligation status once appointed	The rule change does not reduce or modify PMM obligations once appointed, including the 90% intra-day two-sided quoting obligation referenced in the notice.
CMM quoting obligation reference	The notice describes CMMs as required to provide two-sided quotations in 60% of series in each appointed options class under MRX Options 2, Section 5.

Recommended Actions

6 suggested next steps· derived from source analysis

1
AI generatedStep 1 of 6
Update MRX market-structure procedures and control inventories to remove any blanket assumption that every MRX options class must have a PMM.
2
AI generatedStep 2 of 6
Add or validate a reference-data flag showing whether each MRX options class currently has an appointed PMM, if that data is used in routing, surveillance or client disclosures.
3
AI generatedStep 3 of 6
Confirm PMM surveillance remains unchanged for appointed classes, including controls for the 90% intra-day two-sided quoting obligation described in the SEC notice.
4
AI generatedStep 4 of 6
Review CMM quoting surveillance and liquidity dashboards for classes without a PMM, because MRX expects CMM liquidity to operate under existing Options 2, Sections 4 and 5 obligations.
5
AI generatedStep 5 of 6
Brief best-execution and routing governance teams that lack of a PMM appointment is now permitted on MRX and should be assessed through observed liquidity, spreads and execution quality.
6
AI generatedStep 6 of 6
Track SEC action through the 60-day suspension window and monitor comments filed under SR-MRX-2026-35 before treating the change as settled operational policy.

Timeline

effective date

Sep 2, 2026

Nasdaq MRX filed proposed rule change SR-MRX-2026-35 with the SEC; the notice states the rule change became effective under Exchange Act Section 19(b)(3)(A)(iii) and Rule 19b-4(f)(6).

publication

Sep 15, 2026

SEC release date for Notice of Filing and Immediate Effectiveness of SR-MRX-2026-35.

implementation

Oct 2, 2026

The rule change becomes operative 30 days from the September 2, 2026 filing date unless the SEC designates a shorter operative period.

other

Nov 1, 2026

End of the 60-day period from filing during which the SEC may summarily temporarily suspend the rule change under the process described in the notice.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

SEC SRO noticeU.S. Securities and Exchange CommissionSep 15, 2026
Self-Regulatory Organizations; Nasdaq MRX, LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend Options 2, Section 3, Appointment of Market Makers ↗
https://www.sec.gov/files/rules/sro/msrb/2026/34-106387.pdf

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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