CBOE Regulatory Circulars

CBOE Prohibits Multiple EFID Responses to Same Auction

The CBOE exchanges (Cboe Options, C2 Options, BZX Options, and EDGX Options) have clarified that a User may not respond to the same auction through more than one Executing Firm ID (EFID). Users may use different EFIDs to respond to different auctions, but must use only one EFID for any single auction. Responses to the same auction through more than one EFID constitute conduct inconsistent with just and equitable principles of trade and may result in disciplinary action.

Annual CAT Clock Synchronization Certification Reminder

Cboe Exchanges issued Regulatory Circular 26-002 reminding Industry Members of the annual Business Clock Synchronization Certification deadline of March 16, 2026 (extended from March 15, which falls on a Sunday). Under the Exchanges' Consolidated Audit Trail (CAT) Compliance Rules, affected members must maintain certification records internally and make them available to regulators upon request. Members belonging to multiple exchanges or FINRA need only complete a single certification.

Annual Reports Filing Reminder - Electronic Filing Requirements Under SEA Rule 17a-5

CBOE issued Regulatory Circular 26-003 reminding trading permit holders and members of their annual audit report filing obligations under SEA Rule 17a-5. The SEC recently amended filing requirements to mandate electronic submissions via EDGAR in Interactive Data File format. Members must also file electronically with exchanges via FINRA's Firm Gateway.

Position and Exercise Limits for Options on Crypto Assets

Cboe Options Exchanges (Cboe Options, C2 Options, BZX Options, and EDGX Options) amended their rules to remove product-specific 25,000-contract position and exercise limits for options on crypto asset ETFs (Bitcoin and Ethereum trusts). Effective August 6, 2025 and February 24, 2026, the exchanges applied standard position limits under Cboe Options Rule 8.30.02, which may exceed 25,000 contracts based on trading volume factors. FLEX Options trading is now permitted on these crypto assets.

Nomination of Representative Directors for 2026 Annual Meetings

Cboe Exchange, Inc. and affiliated exchanges (Cboe Options, C2 Options, BYX, BZX, EDGA, and EDGX) have announced the nomination of two Representative Directors for election at their 2026 annual meetings. Bruce Andrews and David Roscoe, both current Representative Directors, have been nominated by the Representative Director Nominating Body to continue serving as Non-Industry Directors on each Exchange Board for one-year terms.