[Federal Register Volume 84, Number 128 (Wednesday, July 3, 2019)]
[Notices]
[Pages 31940-31944]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-14164]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-86224; File No. SR-CBOE-2019-030]
Self-Regulatory Organizations; Cboe Exchange, Inc.; Notice of
Filing of a Proposed Rule Change To Use Cboe Exchange's Affiliate, Cboe
Trading, as an Inbound and Outbound Router for Cboe Options
June 27, 2019.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(the ``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that on June 25, 2019, Cboe Exchange, Inc. (the ``Exchange'' or ``Cboe
Options'') filed with the Securities and Exchange Commission (the
``Commission'') the proposed rule change as described in Items I, II,
and III below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
Cboe Exchange, Inc. (the ``Exchange'' or ``Cboe Options'') proposes
to adopt rules related to the inbound and outbound router for Cboe
Options, as well as seek approval from the Securities and Exchange
Commission (``Commission'') for affiliate, [sic] Trading, Inc. (``Cboe
Trading''), to become a Trading Permit Holder of the Exchange. The text
of the proposed rule change is provided in Exhibit 5.
The text of the proposed rule change is also available on the
Exchange's website (http://www.cboe.com/AboutCBOE/CBOELegalRegulatoryHome.aspx), at the Exchange's Office of the
Secretary, and at the Commission's Public Reference Room.
[[Page 31941]]
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the Exchange included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. The Exchange has prepared summaries, set forth in
sections A, B, and C below, of the most significant aspects of such
statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
The Exchange proposes to (1) seek approval from the Commission
pursuant to current Rule 3.32(b) for affiliate, Cboe Trading, to become
a Trading Permit Holder of the Exchange; (2) relocate and amend Rule
3.32(b) related to exchange affiliations to Rule 3.11; (3) adopt Rule
3.12 to govern the Exchange's use of Cboe Trading as an outbound
router; (4) adopt Rule 3.13 to govern the Exchange's receipt of inbound
orders from Cboe Trading, on behalf of the Exchange's affiliate options
exchanges, Cboe EDGX Exchange, Inc. (``EDGX''), Cboe BZX Exchange, Inc.
(``BZX'') and Cboe C2 Exchange, Inc. (``C2''); and (5) make non-
substantive changes to Rule 6.14B regarding non-affiliated routing
brokers. The Exchange notes that proposed Rules 3.11, 3.12 and 3.13 and
current Rule 6.14B are substantively identical in all material respects
to EDGX Rules 2.10, 2.11, 2.12, and 21.9(e), as well as C2 Rules 3.16,
3.17, 3.18 and 6.15(e).
Commission Approval Under Current Rule 3.32(b)
Current Rule 3.32(b) provides that without prior Commission
approval, no Trading Permit Holder may be or become affiliated with the
Exchange. The Exchange seeks Commission approval for Exchange affiliate
Cboe Trading to become a Trading Permit Holder of the Exchange pursuant
to Rule 3.32(b). The Exchange also seeks Commission approval to
transfer and amend current Rule 3.32(b) to proposed Rule 3.11, as
described below.
Relocation and Amendment of Rule 3.32(b)
The Exchange seeks the Commission's approval to relocate Rule
3.32(b) \3\ to proposed new Rule 3.11 and add to proposed Rule 3.11
similar exclusions from the affiliation prohibition contained in its
affiliated options exchanges, EDGX Rule 2.10 and C2 Rule 3.16. Current
Rule 3.32(b) prohibits the Exchange from acquiring or maintaining an
ownership interest in a Trading Permit Holder, as well as prohibits
Trading Permit Holder affiliations with the Exchange or an affiliate of
the Exchange without prior Commission approval. Current exceptions
include equity interests in CBSX LLC and the Exchange's parent company,
Cboe Global Markets, Inc., and affiliations with OneChicago, LLC. EDGX
Rule 2.10 and C2 Rule 3.16 contain similar restrictions on Exchange
affiliations with EDGX Members and C2 Trading Permit Holders, but also
contains additional exceptions, including (a) affiliations solely by
reason of a Member (or any officer, director, manager, managing member,
partner, or affiliate of such Member) becoming a director of the
Exchange or Cboe Global Markets, Inc., or (b) affiliations with Cboe
Trading or of Cboe EDGA Exchange, Inc., Cboe EDGX Exchange, Inc., Cboe
BZX Exchange, Inc., Cboe BYX Exchange, Inc., Cboe C2 Exchange, Inc., or
Cboe Futures Exchange, LLC (each, a ``Cboe Exchange''). The Exchange
proposes to include these two additional exceptions in proposed Rule
3.11 as the same affiliate restrictions apply to all three exchanges
and are consistent with governing documents of Cboe Options and Cboe
Global Markets, Inc., previously filed with the Commission.
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\3\ And, as a result, update the subsequent lettering under Rule
3.32.
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Proposed Rule 3.12 (Cboe Trading as Outbound Router)
The proposed rule change also adopts Rule 3.12 to govern the
Exchange's use of Cboe Trading as an outbound router. Proposed Rule
3.12 is based on EDGX Rule 2.11 and C2 Rule 3.17. As long as Cboe
Trading is affiliated with Cboe Options and is providing outbound
routing of orders from Cboe Options to other securities exchanges,
facilities of securities exchanges, automated trading systems,
electronic communications networks or other brokers or dealers
(``Trading Centers'' and, such function of Cboe Trading is referred to
as the ``Outbound Router''), Cboe Trading's outbound routing services
would be subject to the following conditions and limitations:
Cboe Options will regulate the Outbound Router function of
Cboe Trading as a facility (subject to Section 6 of the Act), and will,
among other things, be responsible for filing with the Commission rule
changes and fees relating to the Cboe Trading Outbound Router function
and Cboe Trading will be subject to exchange non-discrimination
requirements;
FINRA, a self-regulatory organization unaffiliated with
the Exchange or any of its affiliates, will carry out oversight and
enforcement responsibilities as the designated examining authority
designated by the Commission pursuant to Rule 17d-1 of the Act with the
responsibility for examining Cboe Trading for compliance with
applicable financial responsibility rules.
A Trading Permit Holder's use of Cboe Trading to route
orders to another Trading Center will be optional. Any Trading Permit
Holder that does not want to use Cboe Trading may use other routers to
route orders to other Trading Centers.
Cboe Trading will not engage in any business other than
(i) its Outbound Router function, (ii) its Inbound Router function as
described in Rule 3.13, (iii) its usage of an error account in
compliance with proposed paragraph (a)(7) (regarding Cboe Trading
maintenance of an error account described below), and (iv) any other
activities it may engage in as approved by the Commission.
The Exchange will establish and maintain procedures and
internal controls reasonably designed to adequately restrict the flow
of confidential and proprietary information between the Exchange and
its facilities (including Cboe Trading), and any other entity,
including any affiliate of Cboe Trading, and, if Cboe Trading or any of
its affiliates engages in any other business activities other than
providing routing services to the Exchange, between the segment of Cboe
Trading or its affiliate that provides the other business activities
and the routing services.
The Exchange or Cboe Trading may cancel orders as either
deems to be necessary to maintain fair and orderly markets if a
technical or systems issue occurs at the Exchange, Cboe Trading, or a
routing destination. The Exchange or Cboe Trading will provide notice
of the cancellation to affected Trading Permit Holders as soon as
practicable.
Proposed Rule 3.12(a)(7) provides that Cboe Trading will
maintain an error account for the purpose of addressing
[[Page 31942]]
positions that are the result of an execution or executions that are
not clearly erroneous under Rule 6.25 and result from a technical or
systems issue at Cboe Trading, the Exchange, a routing destination, or
a non-affiliate third-party Routing Broker that affects one or more
orders (``Error Positions'').
For purposes of proposed Rule 3.12(a)(7), an Error
Position will not include any position that results from an order
submitted by a Trading Permit Holder to the Exchange that is executed
on the Exchange and automatically processed for clearance and
settlement on a locked-in basis.
Except as provided in proposed subparagraph (7)(C)
(described in the next bullet), Cboe Trading does not accept any
positions in its error account of a Trading Permit Holder or permit any
Trading Permit Holder to transfer any positions from the Trading Permit
Holder's account to Cboe Trading's error account.
If a technical or systems issue results in the Exchange
not having valid clearing instructions for a Trading Permit Holder to a
trade, Cboe Trading may assume the Trading Permit Holder's side of the
trade so that the trade can be automatically processed for clearance
and settlement on a locked-in basis.
In connection with a particular technical or systems
issue, Cboe Trading or the Exchange will either assign all resulting
Error Positions to the Trading Permit Holders in accordance with
proposed subparagraph (D)(i),\4\ or have all resulting Error Positions
liquidated in accordance with proposed subparagraph (D)(ii).\5\ Any
determination to assign or liquidate Error Positions, as well as any
resulting assignments, will be made in a nondiscriminatory fashion.
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\4\ Proposed subparagraph (a)(7)(D)(i) states Cboe Trading or
the Exchange will assign all Error Positions resulting from a
particular technical or systems issue to the Trading Permit Holders
affected by that technical or systems issue if Cboe Trading or the
Exchange (a) determines it has accurate and sufficient information
(including valid clearing information) to assign the positions to
all of the Trading Permit Holders affected by that technical or
systems issue; (b) determines it has sufficient time pursuant to
normal clearance and settlement deadlines to evaluate the
information necessary to assign the positions to all of the Trading
Permit Holders affected by that technical or systems issue; and (c)
has not determined to cancel all orders affected by that technical
or systems issue in accordance with proposed subparagraph (a)(6).
\5\ Proposed subparagraph (a)(7)(D)(ii) states if Cboe Trading
or the Exchange is unable to assign all Error Positions resulting
from a particular technical or systems issue to all of the affected
Trading Permit Holders in accordance with proposed subparagraph (D),
or if Cboe Trading or the Exchange determines to cancel all orders
affected by the technical or systems issue in accordance with
proposed subparagraph (a)(6), then Cboe Trading will liquidate any
applicable Error Positions as soon as practicable. In liquidating
such Error Positions, Cboe Trading will (a) provide complete time
and price discretion for the trading to liquidate the Error
Positions to a third-party broker-dealer and not attempt to exercise
any influence or control over the timing or methods of such trading;
and (b) establish and enforce policies and procedures that are
reasonably designed to restrict the flow of confidential and
proprietary information between the third-party broker-dealer and
Cboe Trading/the Exchange associated with the liquidation of the
Error Positions.
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Cboe Trading and the Exchange will make and keep records
to document all determinations to treat positions as Error Positions
and all determinations for the assignment of Error Positions to Trading
Permit Holders or the liquidation of Error Positions, as well as
records associated with the liquidation of Error Positions through the
third-party broker-dealer.
The books, records, premises, officers, agents, directors,
and employees of Cboe Trading as a facility of the Exchange are deemed
to be the books, records, premises, officers, agents, directors, and
employees of the Exchange for purposes of, and subject to oversight
pursuant to, the Exchange Act. The books and records of Cboe Trading as
a facility of the Exchange are subject at all times to inspection and
copying by the Exchange and the Commission. Nothing in the Rules
precludes officers, agents, directors, or employees of the Exchange
from also serving as officers, agents, directors, and employees of Cboe
Trading.
The Exchange will comply with the above-listed conditions prior to
offering outbound routing from Cboe Trading. In meeting the conditions,
the Exchange will have mechanisms in place to protect the independence
of the Exchange's regulatory responsibility with respect to Cboe
Trading, as well as demonstrate the Cboe Trading cannot use any
information that it may have because of its affiliation with the
Exchange to its advantage. Current Rule 3.32(b) and proposed Rule 3.11
provide that without prior Commission approval, no Trading Permit
Holder may be or become affiliated with the Exchange.
Proposed Rule 3.13 (Cboe Trading as Inbound Router)
The Exchange also proposes to adopt Rule 3.13, which is based on
EDGX Rule 2.12 and C2 Rule 3.18. Pursuant to proposed Rule 3.13, Cboe
Trading's inbound routing services from EDGX Options, BZX Options and
C2 to the Exchange would be subject to the following conditions and
limitations:
The Exchange must enter into a plan pursuant to Rule 17d-2
under the Exchange Act with a non-affiliated self-regulatory
organization and a regulatory services contract with a non-affiliated
SRO to perform regulatory responsibilities for Cboe Trading for unique
Exchange rules.
The regulatory services contract must require the Exchange
to provide the non-affiliated self-regulatory organization with
information, in an easily accessible manner, regarding all exception
reports, alerts, complaints, trading errors, cancellations,
investigations, and enforcement matters (collectively, ``Exceptions'')
in which Cboe Trading is identified as a participant that has
potentially violated Exchange or Commission rules, and shall require
that the non-affiliated self-regulatory organization provide a report
to the Exchange quantifying all such exception reports, alerts,
complaints, trading errors, cancellations, investigations and
enforcement matters on not less than a quarterly basis.
The Exchange, on behalf of its parent company, Cboe Global
Markets, must establish and maintain procedures and internal controls
reasonably designed to ensure that Cboe Trading does not develop or
implement changes to its systems on the basis of nonpublic information
obtained as a result of its affiliation with the Exchange until such
information is available generally to similarly situated Trading Permit
Holders of the Exchange.
If the Exchange complies with the above-listed conditions and if
Cboe Trading operates as an Outbound Router on behalf of each Cboe
Exchange in accordance with the rules of each Cboe Exchange, Cboe
Trading may provide inbound routing services to the Exchange from each
Cboe Exchange.
Proposed Change to Rule 6.14B
Additionally, the Exchange proposes to amend Rule 6.14B to account
for its use of affiliate Cboe Trading as an outbound router, as
proposed, by specifying that the rule applies to the Exchange's non-
affiliated routing brokers. Current Rule 6.14B describes the procedures
and requirements for routing brokers that automatically route
intermarket sweep orders to other Exchanges (``Routing Services''). The
introductory paragraph under Rule 6.14B states that the Exchange may
automatically route intermarket sweep orders to other exchanges under
certain circumstances, and that certain requirements (provided in
subparagraphs (a) through (h)) apply in connection with such services.
Current paragraph (a) states that Routing Services will be provided in
conjunction with one or more routing
[[Page 31943]]
brokers that are not affiliated with the Exchange. Therefore, this rule
is currently applicable to non-affiliated routing brokers and the
Exchange now proposes to merely provide additional clarity regarding
its application to non-affiliated routing brokers in light of proposed
use of affiliate Cboe Trading as an outbound router. The Exchange
proposes to move language in paragraph (a), stated above, to the
introductory provision under 6.14B and amend such language to provide
that Routing Services may be provided in conjunction with one or more
routing brokers that are not affiliated with the Exchange. This
proposed change accounts for proposed Rule 3.12 in which affiliate Cboe
Trading may also provide outbound routing. The Exchange also proposes
to specify in the introductory rule text under Rule 6.14B that the
conditions in the following subparagraphs apply to non-affiliated
routing brokers, as well as update the rule heading accordingly. The
Exchange notes that this proposed change does not substantively alter
any of the conditions listed which are already applicable to non-
affiliated routing brokers and that C2 Rule 6.15(e) and EDGX Options
Rule 21.9(e), provide the same conditions for their non-affiliated
routing brokers.\6\
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\6\ The Exchange notes that the corresponding rules on EDGX
Options and C2 treat their non-affiliated routing brokers as ``back-
up'' routing brokers to their affiliate, Cboe Trading. The Exchange,
however, does not propose to add that its non-affiliated routing
brokers will function as back-up routing brokers, as the Exchange
currently has Routing Service agreements in place today with non-
affiliated and such non-affiliated routing brokers will continue to
function on the Exchange as they have prior to this proposed rule
change.
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The Exchange also proposes to add the definition of ``Cboe
Trading'' to mean Cboe Trading, Inc. to Rule 1.1.
2. Statutory Basis
The Exchange believes the proposed rule change is consistent with
the Securities Exchange Act of 1934 (the ``Act'') and the rules and
regulations thereunder applicable to the Exchange and, in particular,
the requirements of Section 6(b) of the Act.\7\ Specifically, the
Exchange believes the proposed rule change is consistent with the
Section 6(b)(5) \8\ requirements that the rules of an exchange be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, to foster cooperation
and coordination with persons engaged in regulating, clearing,
settling, processing information with respect to, and facilitating
transactions in securities, to remove impediments to and perfect the
mechanism of a free and open market and a national market system, and,
in general, to protect investors and the public interest. Additionally,
the Exchange believes the proposed rule change is consistent with the
Section 6(b)(5) \9\ requirement that the rules of an exchange not be
designed to permit unfair discrimination between customers, issuers,
brokers, or dealers.
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\7\ 15 U.S.C. 78f(b).
\8\ 15 U.S.C. 78f(b)(5).
\9\ Id.
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In particular, the Exchange believes proposed Rules 3.12 and 3.13
promote the maintenance of a fair and orderly market, the protection of
investors and the public interest, and is in the best interests of the
Exchange and its Trading Permit Holders as it will allow the routing of
orders to and from Trading Centers (including affiliated exchanges BZX
Options, EDGX Options and C2) and the Exchange in the same manner as
each Cboe Exchange currently routes orders. Moreover, in meeting the
requirements of Rule 3.13 (i.e., the 17d-2 plan, the regulatory
services contract, and procedures and internal controls) the Exchange
believes it will have mechanisms in place that protect the independence
of the Exchange's regulatory responsibility with respect to Cboe
Trading, as well as demonstrates that Cboe Trading cannot use any
information that it may have because of its affiliation with the
Exchange to its advantage. Similarly, in meeting the requirements of
Rule 3.12 (i.e., regulation as a facility, FINRA acting as the
designated examining authority, optional use of Cboe Trading as an
outbound router, restrictions on business of Cboe Trading, procedures
and internal controls, cancellation of orders, maintenance of error
account), the Exchange believes it will have mechanisms in place that
protect the independence of the Exchange's regulatory responsibility
with respect to Cboe Trading. It also serves to ensure that Cboe
Trading cannot use any information that it may have because of its
affiliation with the Exchange to its advantage, thus preventing an
unfair burden on competition and unfair discrimination between
customers, issuers, brokers, or dealers. The Exchange also believes
that the proposed definition of Cboe Trading will provide additional
clarity of its Rules for investors.
Additionally, proposed Rule 3.11 incorporates the provisions in
current Rule 3.32(b) related to restrictions on Exchange affiliations
with Trading Permit Holders. As noted above, the provisions related to
Exchange affiliations with Trading Permit Holders (including exceptions
to any restrictions in the Rules) are consistent with the governing
documents of Cboe Options and Cboe Global Markets, Inc. Proposed Rule
3.11 also mirrors EDGX Rule 2.10 and C2 Rule 3.16.
Further, the Exchange believes that the proposed changes to Rule
6.14B provide additional clarity of its Rules for investors,
particularly in connection with the proposed use of affiliate Cboe
Trading as an outbound router. The Exchange notes that Rule 6.14B is
currently applicable to non-affiliated routing brokers and the proposed
change merely seeks to provide specificity regarding its application.
The Exchange also notes that it does not alter any of the conditions
already applicable to non-affiliated routing brokers under Rule 6.14B,
therefore the proposed change does not present any new obligations or
novel issues for non-affiliated routing brokers. The Exchange also
notes that proposed Rules 3.11, 3.12, 3.13, and 6.14B are substantially
similar to corresponding EDGX and C2 rules,\10\ previously approved or
filed with the Exchange. Therefore, the proposed rule will provide
consistent rules and functionality with that of its affiliated options
exchange, thereby benefiting participants across the affiliated
exchanges.
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\10\ See supra note 6.
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B. Self-Regulatory Organization's Statement on Burden on Competition
The Exchange does not believe that the proposed rule change will
impose any burden on competition that is not necessary or appropriate
in furtherance of the purposes of the Act. The Exchange does not
believe the proposed rule change will impose any burden on intramarket
competition that is not necessary or appropriate in furtherance of Act
as the proposed rules are based on the corresponding rules of its
affiliated exchanges which allow Cboe Trading to become a member of the
Exchange. Additionally, the proposed rule change is based on EDGX
Options Rule 2.12 and C2 Rule 3.18, which allow EDGX Options and C2 to
receive options orders from affiliate Cboe Trading on behalf of
affiliate exchanges. The Exchange notes that use of Cboe Trading as an
outbound router is voluntary and available to all participants and also
notes that the proposed changes to Rule 6.14B do not substantively
alter any requirements for non-affiliated routing brokers. Further, the
Exchange does not believe Cboe Trading as an inbound router will impose
any burden on intramarket competition as it does not affect
[[Page 31944]]
incoming orders which will continue to be prioritized and allocated
pursuant to Rule 6.45 (Order and Quote Priority Allocation). Moreover,
the requirements of Rule 3.13 (i.e., the 17d-2 plan, the regulatory
services contract, and procedures and internal controls) help to
prevent an unfair burden on competition and unfair discrimination
between customers, issuers, brokers, or dealers.
The Exchange does not believe that the proposed change will impose
any burden on intermarket competition that is not necessary or
appropriate in furtherance of Act as the Exchange's affiliated options
exchanges have the same rules in place and already route orders using
their affiliate, Cboe Trading, to and from Trading Centers. As stated
above, the Exchange also notes that the proposed rule change ensures
that Cboe Trading cannot use any information that it may have because
of its affiliation with the Exchange to its advantage, thus preventing
an unfair burden on competition.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
The Exchange neither solicited nor received comments on the
proposed rule change.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period up to 90 days (i) as the
Commission may designate if it finds such longer period to be
appropriate and publishes its reasons for so finding or (ii) as to
which the Exchange consents, the Commission will:
A. By order approve or disapprove such proposed rule change, or
B. institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's internet comment form (http://www.sec.gov/rules/sro.shtml); or
Send an email to [email protected]. Please include
File Number SR-CBOE-2019-030 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.
All submissions should refer to File Number SR-CBOE-2019-030. This file
number should be included on the subject line if email is used. To help
the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's internet website (http://www.sec.gov/rules/sro.shtml).
Copies of the submission, all subsequent amendments, all written
statements with respect to the proposed rule change that are filed with
the Commission, and all written communications relating to the proposed
rule change between the Commission and any person, other than those
that may be withheld from the public in accordance with the provisions
of 5 U.S.C. 552, will be available for website viewing and printing in
the Commission's Public Reference Room, 100 F Street NE, Washington, DC
20549, on official business days between the hours of 10:00 a.m. and
3:00 p.m. Copies of the filing also will be available for inspection
and copying at the principal office of the Exchange. All comments
received will be posted without change. Persons submitting comments are
cautioned that we do not redact or edit personal identifying
information from comment submissions. You should submit only
information that you wish to make available publicly. All submissions
should refer to File Number SR-CBOE-2019-030 and should be submitted on
or before July 18, 2019.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\11\
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\11\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019-14164 Filed 7-2-19; 8:45 am]
BILLING CODE 8011-01-P