Symbridge Trust Company LLC and Symbridge LLC (together, “Symbridge”) operate a spot exchange platform (the “Exchange”) and are licensed with the New York Department of Financial Services as a limited purpose trust company and licensed by various state banking regulators to engage in money transmission, respectively. The Exchange provides trading services for digital assets that are deemed to be commodities under federal and state law.
- An accredited investor, in the context of a natural person, includes anyone who:
- earned income that exceeded $200,000 (or $300,000 together with a spouse) in each of the prior two years, and reasonably expects the same for the current year, or
- has a net worth over $1 million, either alone or together with a spouse (excluding the value of the person’s primary residence).
- Entities deemed to be accredited investors include:
- any trust, with total assets in excess of $5 million, not formed specifically to purchase the subject securities, whose purchase is directed by a sophisticated person, or
- any entity in which all of the equity owners are accredited investors.
- In this context, a sophisticated person means the person must have, or the company or private fund offering the securities reasonably believes that this person has, sufficient knowledge and experience in financial and business matters to evaluate the merits and risks of the prospective investment.
- Any natural person who is employed and authorized by a Participant to represent the Participant in Exchange matters pursuant to the terms of the Customer Agreement executed between the Participant and Symbridge.
- Business Day shall mean a day on which Symbridge is open for trading as shall be established, and may be revised from time to time, by Symbridge.
- Orders to buy or sell an asset that must be executed immediately in their entirety; otherwise, the entire order will be cancelled (i.e., no partial execution of the order is allowed).
- Orders to buy or sell an asset that last until the order is completed or canceled.
- Orders to buy or sell an asset that must be executed immediately. Any portion of an Immediate-or-Cancel Order that cannot be filled immediately will be cancelled.
- Orders to buy or sell an asset at a specific price or better.
- Orders to buy or sell an asset immediately.
- Either a bid or an offer for a transaction.
- Any natural person or entity initiating or executing a transaction on or subject to the Rules of the Exchange directly or through an intermediary, or any person who is authorized to access or utilize the Exchange pursuant to a Customer Agreement executed with Symbridge. For the avoidance of doubt a Participant that is a natural person shall only engage in trading activity for themselves.
- Product shall mean any digital assets that is listed for trading on the Exchange.
Rule and/or Rulebook.
- Rules and/or Rulebook shall mean the requirements and practices stated in this document regarding the Exchange.
- Trading Hours shall mean for any Business Day, the hours during which Orders may be placed on the Platform, as shall be established, and may be revised from time to time, by Symbridge.
- Trading Privileges is the right granted to a Participant, by Symbridge, to make use of the trading services offered on the Exchange.
This Rulebook contains the Rules and trading practices regarding trading services provided by Symbridge through use of the Exchange, which may be amended, from time to time, by Symbridge.
Any person initiating or executing a transaction on or subject to the Rules of the Exchange, and any person for whose benefit such a transaction has been initiated or executed, expressly consents to the jurisdiction of the Exchange and agrees to be bound by and comply with the Rules and Symbridge’s Customer Agreement, including, without limitation, those applied pursuant to appliable law.
To be eligible for admission as a Participant, an applicant must demonstrate to the satisfaction of the Exchange that it:
- is of good reputation and business integrity;
- is resident in a jurisdiction in which Symbridge is authorized to operate the Exchange;
- has successfully completed the Exchange’s onboarding process;
- maintains adequate financial resources and credit;
- is an Accredited Investor;
- is of the age of majority in the individual’s state of residence (if an individual);
- if the Participant is an entity, that it is validly organized, in good standing, and authorized by its governing body and, if relevant, documents of organization, to trade assets over the Exchange (if an entity);
- is not prohibited from using the services of the Exchange for any reason whatsoever;
- holds all federal and state regulatory licensures that may be applicable to its business, if any;
- is not subject to any applicable statutory disqualification under the Commodity Exchange Act; and
- satisfies any other criteria that the Exchange may require from a Participant.
Once admitted, the Participant shall continue to comply with all applicable eligibility criteria in this Rule 201. The Exchange evaluates and monitors a Participant’s compliance with the criteria set forth in this Rule 201.
Participants must immediately notify the Exchange in writing upon becoming aware:
- That Participant no longer satisfies the criteria set forth in Rule 201.
- that Participant, or any of its officers or Authorized Users, has made any changes to its customer profile, including its address or contact information, provided in the Customer Agreement executed between Participant and Symbridge;
- that Participant, or any of its officers or Authorized Users, has had trading privileges suspended, or access to, or membership or clearing membership, in any exchange or clearinghouse, as applicable, denied;
- that Participant, or any of its officers or Authorized Users, has been convicted of, pled guilty or no contest to, or entered a plea agreement to any felony in any domestic, foreign or military court, or with a governmental or regulatory authority, as applicable;
- that Participant, or any of its officers or Authorized Users, has been convicted of, plead guilty or no contest to, or entered a plea agreement to a misdemeanor in any domestic, foreign or military court, or with a governmental or regulatory authority, as applicable, which involves embezzlement, theft, extortion, fraud, fraudulent conversion, forgery, counterfeiting, false pretenses, bribery, gambling, racketeering, or misappropriation of funds, securities or properties;
- that Participant, or any of its officers or Authorized Users, has been subject to, or associated with a firm that was subject to regulatory proceedings before any governmental or regulatory authority;
- of any other material change in any information Participant provided to the Exchange;
- of becoming the subject of a bankruptcy petition, receivership proceeding, or the equivalent, or being unable to meet any financial obligation as it becomes due; or
- of information that concerns any financial or business developments that may materially affect your ability to continue to comply with applicable requirements hereunder.
Rule 203 Trading Privileges
- All Trading Privileges granted by Symbridge to Participants are subject to the terms and conditions of this Rulebook.
- Subject to the terms and conditions of this Rulebook, a Participant that is a legal entity may request that Symbridge grant Trading Privileges to one or more Authorized Users. All Authorized Users shall be subject to the Rules of the Exchange.
- Trading Privileges area non-assignable, non-transferable and may not be sold or leased.
- A grant of Trading Privileges does not convey any ownership interest in Symbridge or the Exchange
The Exchange will list and facilitate trading only in products for which it has authorization to do so in the jurisdictions where its services are available. Available products may vary by jurisdiction. The Exchange will provide for trading in the following assets:
- Bitcoin Cash
The Exchange may, without notice to Participant, cease offering trading in any of the products listed in this Rule at any time in any jurisdiction.
Symbridge shall determine the Business Days and Trading Hours for each product traded on the Exchange. Symbridge may vary its Trading Hours among different Products. Orders may not be submitted to the Exchange outside of Trading Hours. Symbridge’s Business Days, Trading Hours and Holiday Calendar, including any changes thereto, shall be published on its website.
Participants are required to take all reasonable and adequate controls to secure and maintain their username and password used to access the Exchange. Symbridge is not liable for any lost user credentials used by Participants to access the Exchange. Participants shall immediately notify Symbridge in the event of any lost or stolen passwords and/or credentials.
The Exchange uses anonymous central limit order books, which provide for electronic listings of pricing on both sides of the relevant markets (i.e. bids and asks). All Orders entered into the Exchange are electronically matched on a price-time-priority basis.
Participants will be able to enter the following order types on the Exchange:
- Market Orders;
- Limit Orders;
- Stop-Loss Orders;
- Take-Profit Orders;
- Good-til-Cancelled Orders;
- Fill-or-Kill Orders; and
- Immediate-or-Cancel Orders.
Once an Order is entered by a Participant into the Exchange, the Order is executable and the relevant Participant is responsible for the settlement of such Order if it is matched. Participants are allowed to modify or cancel an Order at any time prior that Order being matched on the Exchange. If an Order is matched on the Exchange before Symbridge receives notice of a cancellation or modification from a Participant, that Order shall be matched and settled as required by the Order’s initial terms.
Participants have an affirmative obligation to maintain sufficient resources in their account(s) on the Exchange to settle any transactions for which they place and Order. Settlement of all trades over the Exchange occurs in real time once a trade is matched and validated. If a Participant fails to maintain sufficient resources to settle a trade on the Exchange, such Participant may have its access to the Exchange limited and/or terminated, in the sole discretion of Symbridge.
All trading fees are disclosed on Symbridge’s website at www.symbridge.com.
It shall be a violation for a Participant (and/or any of its Authorized Users) to violate any Rule contained in this Rulebook or any agreement made with Symbridge, or to engage in fraud, dishonorable or dishonest conduct, or in conduct which is inconsistent with just and equitable principles of trade.
Participants shall not:
- Use, attempt to use or assist in the use of, any manipulative device to defraud and/or distribute or disseminate any unlawful material and/or information;
- Manipulate, attempt to manipulate or assist in the manipulation of the price of any Product;
- Engage in disruptive trading activity, or attempt to engage or assist in engaging in disruptive trading activity, including without limitation spoofing and wash trading.
- engage in any activities deemed to be “Prohibited Uses” in the Customer Agreement executed between the Participant and Symbridge. Such activities include, but are not limited to, spoofing, fraud, and other abusive activities;
- engage in activity that violates, or attempts to violate or assists in the violation of any law, ordinance, regulation, statute, sanctions program administered in any jurisdiction in which the Exchange operates, including without limitation the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”);
- Engaging in, attempting to engage in or assist in engaging in, any activity that involves the proceeds of unlawful activity; or
- engage in any activities deemed to be “Prohibited Uses” in the Customer Agreement between the Participant and Symbridge.
No Participant shall execute or cause to be executed or participate in an account for which there are executed purchases of any asset on the Exchange at successively higher prices, or sales of any asset on the Exchange at successively lower prices, for the purpose of creating or inducing a false, misleading or artificial appearance of activity in such asset on the Exchange or for the purpose of unduly or improperly influencing the market price for such asset or for the purpose of establishing a price which does not reflect the true state of the market in such asset.
No Participant, for the purpose of creating or inducing a false or misleading appearance of activity in an asset traded on the Exchange or creating or inducing a false or misleading appearance with respect to the market in such asset shall:
- execute any transaction in such asset which involves no change in the beneficial ownership thereof, or
- enter any order or orders for the purchase of such asset with the knowledge that an order or orders of substantially the same size, and at substantially the same price, for the sale of such asset, has been or will be entered by or for the same or different parties, or
- enter any order or orders for the sale of any such asset with the knowledge that an order or orders of substantially the same size, and at substantially the same price, for the purchase of such Security, has been or will be entered by or for the same or different parties.
- No Participant shall participate or have any interest, directly or indirectly, in the profits of a manipulative operation or knowingly manage or finance a manipulative operation.
- Any pool, syndicate or joint account organized or used intentionally for the purpose of unfairly influencing the market price of an asset shall be deemed to be a manipulative operation.
- The solicitation of subscriptions to or the acceptance of discretionary orders from any such pool, syndicate or joint account shall be deemed to be managing a manipulative operation.
- The carrying on margin of a position in such Participant or the advancing of credit through loans to any such pool, syndicate or joint account shall be deemed to be financing a manipulative operation.
- In addition to the prohibited practices set forth in Chapter 5 of this Rulebook, no participant shall engage in any activities deemed to be “Prohibited Uses” in the Customer Agreement executed between the Participant and Symbridge. Such activities include, but are not limited to, spoofing, fraud, and other abusive activities.
The Chief Compliance Officer shall have the authority and resources to enforce the Rules and conduct investigations of any potential or alleged violations of the Rules, improper trading activity, unusual market conditions and/or any suspicious activity.
All Participants must undergo anti-money laundering screening and ongoing monitoring by Symbridge in order to access the Exchange. Symbridge may deny access to the Exchange if it determines, in its sole discretion as part of this screening and ongoing monitoring, that Participant or its Authorized Users have engaged in money laundering activity through the Exchange.
The Exchange will comply with the Financial Action Task Force’s Travel Rule.
All Participants and all employees, agents, vendors, and other Persons affiliated with the foregoing understand and acknowledge that the Exchange has a proprietary interest in:
- the price and quantity data from each and every transaction executed on the Exchange, including the time at which the transaction was executed by, or submitted to, the Exchange;
- the price and quantity data for each and every bid and offer submitted for entry into the Exchange, including the time at which the bid and offer was entered into the Exchange;
- the daily settlement price of each transaction facilitated over the Exchange;
- any data and information derived from (1), (2) and (3) and the format and presentation thereof; and
- the transmissions and dissemination of the data and information to Participants any publisher of the data or information with whom the Exchange has a written agreement, and any other persons.
Participants may not distribute, sell or retransmit information displayed on the Exchange to any third party. Notwithstanding the foregoing, Participants may distribute, sell, or retransmit market data pursuant to a duly executed market data agreement.
Symbridge may amend this Rulebook from time to time. All notices relevant to the Exchange, including those relating to amendments to this Rulebook, will be posted on the Symbridge website and will be effective as of the date indicated on the notice.