Points Program

Participation in the Novig Points Program is governed by these Terms and Conditions, together with the Ludlow Rulebook (the "Rulebook") and the Ludlow Member Agreement (the "Member Agreement"), including the MANDATORY ARBITRATION and CLASS ACTION WAIVER provisions in Sections 22–25 of the Member Agreement, by which you remain bound. Please read them carefully. Capitalized terms used but not defined here have the meanings given in the Rulebook and the Member Agreement.

How It Works

Opt in, then earn Points on your eligible executed trading activity. Points move you through monthly tiers. Each tier you reach unlocks rewards in the form of Trade Credits, Deposit Matches, or both, and every Participating Member who reaches a tier also shares in that month’s Incentive Fund, paid as Trade Credits. Points are used only to determine your tier for the month; they have no cash value and cannot be withdrawn.

1. Description of Program

Welcome to the Novig Points Program (the "Program"), where Members who opt in and meet the eligibility requirements may accrue points ("Points," referred to as “Qualifying Volume” in the Points Program Incentive Filing), reach monthly tiers, and unlock rewards based on their monthly activity. The Program is offered by Ludlow Exchange, LLC, d/b/a Novig ("Novig" or the "Exchange"), a Commodity Futures Trading Commission-designated contract market, located at 169 Madison Avenue #2199, New York, NY 10016. The terms "you" or "your" mean the Member who participates in the Program. Participation in the Program is voluntary and requires affirmative opt-in, and is expressly conditioned upon acceptance of and compliance with these Terms and Conditions (these "Terms"), the Rulebook, and the Member Agreement. The terms of the Program that Novig has filed with the Commodity Futures Trading Commission (the "Points Program Incentive Filing") are available at https://www.ludlowexchange.com/filings. Points have no cash value and cannot be transferred or withdrawn. ANY DISPUTE RELATING TO THIS PROGRAM WILL BE RESOLVED IN ACCORDANCE WITH SECTION 16 BELOW, AND PARTICIPANTS WAIVE THE ABILITY TO BRING CLAIMS IN A CLASS ACTION FORMAT.

2. Acceptance of Terms

By opting in to, accessing, or participating in the Program, including by earning Points, you acknowledge that you have read, understood, and agree to be bound by these Terms, the Rulebook, and the Member Agreement, as each may be amended from time to time. To the extent of any conflict, the Points Program Incentive Filing controls, followed by the order of precedence set forth in the Member Agreement (Rulebook, then Member Agreement, then these Terms). If you do not agree to these Terms, the Rulebook, and the Member Agreement, you may not participate in the Program.

3. Program Period

The Program operates on monthly cycles (each a "Monthly Period"). Each Monthly Period begins on the first calendar day of a month and ends on the first calendar day of the following month, running from 6:00 AM Eastern Time ("ET") on the first calendar day of the month until 6:00 AM ET on the first calendar day of the following month. Points earned during a Monthly Period determine your tier status for that same Monthly Period, with your tier status updating during the Monthly Period as the applicable Point thresholds set out in the Points Program Incentive Filing are reached. New Participating Members start at the lowest tier and may advance during their first Monthly Period as those thresholds are reached. Point totals used for tier qualification reset to zero at the start of each new Monthly Period and do not carry forward. Each Monthly Period has a separate Incentive Fund, as described in Section 6.

4. Eligibility & Registration

Participation is voluntary and requires affirmative opt-in. A Member becomes a participant (a "Participating Member") only upon opting in, through onboarding or through the Novig app or website. A Member who has not opted in earns no Points and accrues no tier status. A Participating Member may opt out at any time through the Novig app or website. The consequences of opting out are set forth in Section 8.

The Program is open to all Members who opt in and meet the eligibility requirements, except the following, who are not eligible to participate: (i) Affiliates of the Exchange (as defined in the Rulebook); (ii) Members who have executed a market maker agreement or entity onboarding agreement with the Exchange; and (iii) Introducing Brokers ("IBs"), Futures Commission Merchants ("FCMs"), and their customers when transacting via the IB or FCM. All Participating Members remain subject to the Rulebook.

To remain eligible, you must, at the relevant time: (a) maintain an active account that has not been suspended, restricted, or terminated; (b) not be subject to a self-exclusion; (c) be in compliance with the Rulebook in all material respects; and (d) have satisfied all applicable verification requirements imposed by the Exchange or its partner clearinghouse. If you cease to meet these requirements, you will immediately cease to be eligible to earn additional Points, and your Points, tier status, and unredeemed rewards are subject to forfeiture under Section 8.

Successor programs. Your opt-in applies to this Program. If Novig launches a successor incentive program certified under CFTC Regulation 40.6, you must opt in to that program separately to participate in it.

5. Limitations on Participation

In addition to the eligibility requirements in Section 4, the Chief Regulatory Officer may at any time revoke your eligibility and disqualify Trades or activity inconsistent with the purpose of the Program or the Rulebook. This Program is void where prohibited by law.

6. Tiers and Rewards

Accumulated Points within a Monthly Period advance you through tiers. The lowest tier carries no rewards and does not count as reaching a tier for purposes of the rewards and Incentive Fund described in this Section 6. Crossing a tier unlocks rewards in the form of Reward Credits, and you receive the rewards for each tier you reach during a Monthly Period. "Reward Credits" means the Trade Credits and Deposit Matches awarded under the Program. The forms of reward associated with each tier need not be uniform, and not every tier unlocks every form of reward. The Point threshold required to attain each tier, and the rewards associated with each tier, are set out in the Points Program Incentive Filing.

Incentive Fund. At the end of each Monthly Period, Novig will distribute an incentive fund (the "Incentive Fund"), funded by the Exchange, among Participating Members who reach a tier during that Monthly Period, based on the highest tier attained during that Monthly Period, with higher tiers receiving larger shares. The amount of the Incentive Fund and the allocation methodology are set out in the Points Program Incentive Filing. The Incentive Fund is allocated among eligible Participating Members according to a fixed, predetermined methodology that Novig applies on a consistent, non-discriminatory basis to all similarly situated Participating Members. Incentive Fund distributions are paid as Trade Credits, not cash.

7. Restrictions on Redemption

Points are non-transferable, have no cash value, and may not be redeemed for cash or withdrawn from the Exchange. Reward Credits may not be transferred, redeemed for cash, or withdrawn.

Each Reward Credit must be claimed within seven (7) days after it is made available and, once claimed, must be used within seven (7) days after the date it is claimed. Any Reward Credit not timely claimed or used is forfeited. A Trade Credit may be applied only to a single Trade priced between $0.01 and $0.60, must be applied in full to that Trade, and any unused portion is forfeited. Trade Credits may not be used through programmatic or automated trading. A Deposit Match is a promotional credit that matches your qualifying deposit up to the amount for the applicable tier. A Deposit Match is available for one-time use; once claimed, the matched amount is final and may not be supplemented by, or applied to, any subsequent deposit.

Distributions from the Incentive Fund, once credited as a Trade Credit to your Exchange account, are subject to the withdrawal terms set forth in the Rulebook and the Member Agreement.

8. Forfeiture, Adjustment, and Recovery

8.1. Forfeiture. Upon (a) closure, suspension, or termination of your account; (b) your becoming subject to a self-exclusion; (c) your opt-out from the Program; or (d) termination of the Program, any Points accumulated during the applicable Monthly Period cease to count for purposes of the Program and any unclaimed or unused Reward Credits are forfeited.

8.2. Restoration. Novig may restore Points or Reward Credits forfeited under this Section in exceptional circumstances. Any restoration request must be submitted to [email protected] within thirty (30) days of the event giving rise to the forfeiture. Novig's determination on any request for restoration is final.

8.3. Adjustment and Recovery. Novig may adjust or cancel Points and may reverse or recover any Reward Credit where: (i) they were calculated or credited in error, including as a result of a technical malfunction, system error, inaccurate data feed, or administrative mistake; (ii) the Trade or transaction giving rise to the Points or Reward Credit has been voided or cancelled; (iii) a payment or deposit associated with the Reward Credit is charged back or otherwise not honored; (iv) Novig determines that they resulted from fraud, misrepresentation, collusion, multi-accounting, or other activity inconsistent with the Rulebook or the Program; or (v) the adjustment, reversal, or recovery is required by Applicable Law or by directive of a competent regulatory authority.

8.4. No Vested Rights. Points and tier status do not constitute your property, have no cash value, and are not transferable. You have no vested right in any Points balance or tier status.

9. Program Changes & Termination

The Chief Regulatory Officer retains sole discretion to revoke a Participating Member's eligibility, disqualify Trades or activity inconsistent with the purpose of the Program or the Rulebook, and modify, suspend, or terminate the Program at any time. Novig may end the Program at any time. Any change to the terms of the Program will be made by a new self-certification filing under CFTC Regulation 40.6 and not by amendment of the Program; the fixed values set out in the Points Program Incentive Filing apply for the term of the Program. Where reasonably practicable, Novig will provide advance notice of material changes by notice on the Novig website, in-app notification, or email; Novig may make immediate changes required by Applicable Law or regulatory directive. Novig conducts ongoing surveillance of Program activity pursuant to Chapter 9 of the Rulebook. Where the Chief Regulatory Officer concludes that a Participating Member's participation is abusive or otherwise inconsistent with the purpose of the Program, that Member's Points, tier status, and any unredeemed rewards are automatically forfeited to the Exchange.

10. Self-Exclusion

If you are subject to a self-exclusion, you are ineligible to participate in the Program for the duration of that exclusion, and your Points, tier status, and unredeemed rewards are subject to forfeiture under Section 8. Novig may immediately suspend your ability to earn Points upon becoming aware of a self-exclusion, without prior notice.

11. Privacy & Data Use

Participation in the Program is subject to the Novig Privacy Policy (the "Privacy Policy"), which is incorporated into the Member Agreement. By participating, you acknowledge that Novig may collect, use, and process data generated through Program participation, including Points-earning activity and tier status, in accordance with the Privacy Policy.

12. Intellectual Property

All names, marks, logos, Program mechanics, and content associated with the Program are the proprietary intellectual property of Novig and are protected by applicable intellectual property laws. Participation in the Program does not grant you any license or right to use Novig’s intellectual property. You may not reproduce, modify, distribute, or otherwise exploit any Program-related intellectual property without Novig's prior written consent.

13. Tax Disclosure

You are solely responsible for all tax obligations arising from participation in the Program, consistent with Section 5.9 of the Member Agreement.

14. Limitation on Liability

Novig's liability for any Program-related claim is governed by Section 19 of the Member Agreement, which limits liability and disclaims responsibility for, among other things, the loss of any trading incentive or bonus. Points have no cash value, and Novig has no liability for the loss of Points, loss of tier status, or the modification or termination of the Program under Section 9.

15. Complaint & Cancellation

Should you wish to cancel your participation in the Program at any time, please contact [email protected]. Upon cancellation, your Points balance is forfeited in accordance with Section 8. To submit a complaint regarding the Program, contact [email protected] with a description of your complaint and the remedy you are seeking; such complaints are subject to the informal dispute resolution process described in Section 16.

16. Dispute Resolution

Any dispute relating to this Program is a "Dispute" governed by the informal dispute resolution, mandatory arbitration, and class action waiver provisions of the Member Agreement (Sections 22–25) and Chapters 10–11 of the Rulebook, including the opt-out rights and carve-outs set forth therein.

17. General Terms

17.1. Severability. If any provision of these Terms is found invalid or unenforceable, that provision is severed and the remainder continues in full force and effect.

17.2. Waiver. Novig's failure to enforce any provision at any time is not a waiver of its right to do so later.

17.3. Entire Agreement. These Terms, together with the Rulebook, the Member Agreement, and the Privacy Policy, constitute the entire agreement between the parties with respect to the Program and supersede all prior understandings relating to the Program.

17.4. Survival. Sections 8, 12, 13, 14, 15, 16, and this Section 17 survive termination of the Program or these Terms.

17.5. Assignment. Novig may assign these Terms without notice or your consent. You may not assign your Program participation, account, or Points balance; any purported assignment by you is void.

17.6. Amendments. Any change to the terms of the Program will be made only by a new self-certification filing, as described in Section 9. Novig may otherwise update these Terms to correct errors or improve clarity, consistent with the Points Program Incentive Filing, with updates reflected on the Novig platform. Your continued participation after an update is posted constitutes acceptance.

17.7. Governing Law. These Terms are governed by the laws of the State of New York, consistent with Section 34 of the Member Agreement.

17.8. Indemnification and Limitation of Liability. Your indemnification obligations under Section 18 of the Member Agreement, and the limitation of liability set forth in Rule 12.3 of the Rulebook, apply in full to your participation in the Program.