Information Notice - 1/3/25
Executive Summary
FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
What Changed
The primary regulatory modification addresses a single-day exception to standard options exercise procedures: - CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. - Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. - OCC Processing Unchanged: The Options Clearing Corporation's processing timeframes remained unaffected by the market closure. - Restricted Exercise Classes: Exercises in non-expiring American-style, cash-settled index options and non-expiring American-style, cash-settled FLEX ETF option classes were prohibited on January 9, 2025, due to the national option
What You Need To Do
- *Update Internal Procedures
- *System Configuration
- *Staff Communication
- *Customer Notification
- *Submission Coordination
- *Documentation
Key Dates
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
Who is Affected
Summary
Information Notice - 1/3/25