[Federal Register Volume 90, Number 73 (Thursday, April 17, 2025)]
[Notices]
[Pages 16290-16298]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-06509]


-----------------------------------------------------------------------

SECURITIES AND EXCHANGE COMMISSION

Release No. 34-102831; File No. SR-CBOE-2025-025]


Self-Regulatory Organizations; Cboe Exchange, Inc.; Notice of 
Filing and Immediate Effectiveness of a Proposed Rule Change To Amend 
Its Rules To Allow the Exchange To List Options on the iShares Ethereum 
Trust

April 11, 2025.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that 
on April 9, 2025, Cboe Exchange, Inc. (``Exchange'' or ``Cboe 
Options'') filed with the Securities and Exchange Commission 
(``Commission'') the proposed rule change as described in Items I and 
II below, which Items have been prepared by the Exchange. The Exchange 
filed the proposal as a ``non-controversial'' proposed rule change 
pursuant to Section 19(b)(3)(A)(iii) of the Act \3\ and Rule 19b-
4(f)(6) thereunder.\4\ The Commission is publishing this notice to 
solicit comments on the proposed rule change from interested persons.
---------------------------------------------------------------------------

    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
    \3\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \4\ 17 CFR 240.19b-4(f)(6).
---------------------------------------------------------------------------

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 amend its Rules to allow the Exchange to list options on the iShares 
Ethereum Trust (the ``Trust''). 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.

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 amend Rule 4.3 regarding the criteria for 
underlying securities. Specifically, the Exchange proposes to amend 
Rule 4.3, Interpretation and Policy .06(a)(4) to allow the Exchange to 
list and trade options on Units \5\ that represent interests in the 
Trust. This is a competitive filing based on a similar proposal 
submitted by Nasdaq ISE, LLC (``ISE''), which was recently approved by 
the Securities and Exchange Commission (the ``Commission'').\6\ Current 
Rule 4.3, Interpretation and Policy .06 provides that, subject to 
certain other criteria set forth in that Rule, securities deemed 
appropriate for options trading include Units that represent certain 
types of interests,\7\

[[Page 16291]]

including interests in certain specific trusts that hold financial 
instruments, money market instruments, precious metals (which are 
deemed commodities), or Bitcoin (which is another crypto currency and 
deemed a commodity). In addition, Rule 4.3, Interpretation and Policy 
.06 requires that Units must either (1) meet the criteria and standards 
set forth in Rule 4.3, Interpretation and Policy .01(a),\8\ or (2) be 
available for creation or redemption each business day from or through 
the issuer in cash or in kind at a price related to net asset value, 
and the issuer must be obligated to issue Units in a specified 
aggregate number even if some or all of the investment assets required 
to be deposited have not been received by the issuer, subject to the 
condition that the person obligated to deposit the investments has 
undertaken to deliver the investment assets as soon as possible and 
such undertaking is secured by the delivery and maintenance of 
collateral consisting of cash or cash equivalents satisfactory to the 
issuer, as provided in the respective prospectus.
---------------------------------------------------------------------------

    \5\ Rule 1.1 defines a ``Unit'' (which may also be referred to 
as an ETF) as a share or other security traded on a national 
securities exchange and defined as an NMS stock as set forth in Rule 
4.3.
    \6\ See Securities Exchange Act Release No. 100661 (August 6, 
2024), 89 FR 65690 (August 12, 2024) (SR-ISE-2024-35); and 
Securities Exchange Act Release No. 102798 (April 9, 2025) (``ISE 
Approval'').
    \7\ See Rule 4.3, Interpretation and Policy .06(a), which 
permits options trading on Units that represent (1) interests in 
registered investment companies (or series thereof) organized as 
open-end management investment companies, unit investment trusts or 
similar entities that hold portfolios of securities and/or financial 
instruments including, but not limited to, stock index futures 
contracts, options on futures, options on securities and indexes, 
equity caps, collars and floors, swap agreements, forward contracts, 
repurchase agreements and reverse purchase agreements (the 
``Financial Instruments''), and money market instruments, including, 
but not limited to, U.S. government securities and repurchase 
agreements (the ``Money Market Instruments'') comprising or 
otherwise based on or representing investments in indexes or 
portfolios of securities and/or Financial Instruments and Money 
Market Instruments (or that hold securities in one or more other 
registered investment companies that themselves hold such portfolios 
of securities and/or Financial Instruments and Money Market 
Instruments); (2) interests in a trust or similar entity that holds 
a specified non-U.S. currency deposited with the trust or similar 
entity when aggregated in some specified minimum number may be 
surrendered to the trust by the beneficial owner to receive the 
specified non-U.S. currency and pays the beneficial owner interest 
and other distributions on deposited non-U.S. currency, if any, 
declared and paid by the trust (``Currency Trust Shares''); (3) 
commodity pool interests principally engaged, directly or 
indirectly, in holding and/or managing portfolios or baskets of 
securities, commodity futures contracts, options on commodity 
futures contracts, swaps, forward contracts and/or options on 
physical commodities and/or non-U.S. currency (``Commodity Pool 
Units''); (4) interests in the SPDR Gold Trust, the iShares COMEX 
Gold Trust, the iShares Silver Trust, the Aberdeen Standard Physical 
Silver Trust, the Aberdeen Standard Physical Gold Trust, the 
Aberdeen Standard Physical Palladium Trust, the Aberdeen Standard 
Physical Platinum Trust, the Sprott Physical Gold Trust, the Goldman 
Sachs Physical Gold ETF, the Fidelity Wise Origin Bitcoin Fund, the 
ARK 21Shares Bitcoin ETF, the iShares Bitcoin Trust, the Grayscale 
Bitcoin Trust, the Grayscale Bitcoin Mini Trust, or the Bitwise 
Bitcoin ETF; or (5) an interest in a registered investment company 
(``Investment Company'') organized as an open-end management 
investment company or similar entity, that invests in a portfolio of 
securities selected by the Investment Company's investment adviser 
consistent with the Investment Company's investment objectives and 
policies, which is issued in a specified aggregate minimum number in 
return for a deposit of a specified portfolio of securities and/or a 
cash amount with a value equal to the next determined net asset 
value (``NAV''), and when aggregated in the same specified minimum 
number, may be redeemed at a holder's request, which holder will be 
paid a specified portfolio of securities and/or cash with a value 
equal to the next determined NAV (``Managed Fund Share'').
    \8\ Rule 4.3, Interpretation and Policy .01 provides for 
guidelines to be by the Exchange when evaluating potential 
underlying securities for Exchange option transactions.
---------------------------------------------------------------------------

    The Exchange proposes to add the Trust to the list of Units on 
which the Exchange may list options in Rule 4.3, Interpretation and 
Policy .06(a)(4). The shares are issued by the Trust, a Delaware 
statutory trust. The Trust will operate pursuant to a trust agreement 
(the ``Trust Agreement'') between the Sponsor, BlackRock Fund Advisors 
(the ``Trustee'') as the trustee of the Trust and will appoint 
Wilmington Trust, National Association, as Delaware Trustee of the 
Trust (the ``Delaware Trustee'') by such time that the Registration 
Statement is effective. The Trust issues Shares representing fractional 
undivided beneficial interests in its net assets. The assets of the 
Trust will consist only of ether (``ether'' or ``ETH'') held by a 
custodian on behalf of the Trust, except under limited circumstances 
when transferred through the Trust's prime broker temporarily 
(described below), and cash. Neither the Trust, nor the Sponsor, nor 
the Ether Custodian (as defined below), nor any other person associated 
with the Trust will, directly or indirectly, engage in action where any 
portion of the Trust's ETH becomes subject to the Ethereum proof-of-
stake validation or is used to earn additional ETH or generate income 
or other earnings. Coinbase Custody Trust Company, LLC (the ``Ether 
Custodian''), is the custodian for the Trust's ether holdings, and 
maintains a custody account for the Trust (``Custody Account''); 
Coinbase, Inc. (the ``Prime Execution Agent''), an affiliate of the 
Ether Custodian, is the prime broker for the Trust and maintains a 
trading account for the Trust (``Trading Account''); and The Bank of 
New York Mellon is the custodian for the Trust's cash holdings (the 
``Cash Custodian'' and together with the Ether Custodian, the 
``Custodians'') and the administrator of the Trust (the ``Trust 
Administrator''). Under the Trust Agreement, the Trustee may delegate 
all or a portion of its duties to any agent, and has delegated the bulk 
of the day-to-day responsibilities to the Trust Administrator and 
certain other administrative and record-keeping functions to its 
affiliates and other agents. The Trust is not an investment company 
registered under the Investment Company Act of 1940, as amended (the 
``1940 Act'').
    The investment objective of the Trust is to reflect generally the 
performance of the price of ether. The Trust seeks to reflect such 
performance before payment of the Trust's expenses and liabilities. The 
Shares are intended to constitute a simple means of making an 
investment similar to an investment in ether through the public 
securities market rather than by acquiring, holding and trading ether 
directly on a peer-to-peer or other basis or via a digital asset 
platform. The Shares have been designed to remove the obstacles 
represented by the complexities and operational burdens involved in a 
direct investment in ether, while at the same time having an intrinsic 
value that reflects, at any given time, the investment exposure to the 
ether owned by the Trust at such time, less the Trust's expenses and 
liabilities. Although the Shares are not the exact equivalent of a 
direct investment in ether, they provide investors with an alternative 
method of achieving investment exposure to ether through the public 
securities market, which may be more familiar to them.
    An investment in the Shares is backed by ether held by the Ether 
Custodian on behalf of the Trust. All of the Trust's ether will be held 
in the Custody Account, other than the Trust's ether which is 
temporarily maintained in the Trading Account under limited 
circumstances, i.e., in connection with creation and redemption Basket 
\9\ activity or sales of ether deducted from the Trust's holdings in 
payment of Trust expenses or the Sponsor's fee (or, in extraordinary 
circumstances, upon liquidation of the Trust). The Custody Account 
includes all of the Trust's ether held at the Ether Custodian, but does 
not include the Trust's ether temporarily maintained at the Prime 
Execution Agent in the Trading Account from time to time. The Ether 
Custodian will keep all of the private keys associated with the Trust's 
ether held in the Custody Account in ``cold storage''.\10\ The 
hardware, software, systems, and procedures of the Ether Custodian may 
not be available or cost-effective for many investors to access 
directly.
---------------------------------------------------------------------------

    \9\ The Trust issues and redeems Shares only in blocks of 40,000 
or integral multiples thereof. A block of 40,000 Shares is called a 
``Basket.'' These transactions take place in exchange for ether.
    \10\ The term ``cold storage'' refers to a safeguarding method 
by which the private keys corresponding to the Trust's ether are 
generated and stored in an offline manner, subject to layers of 
procedures designed to enhance security. Private keys are generated 
by the Ether Custodian in offline computers that are not connected 
to the internet so that they are more resistant to being hacked.
---------------------------------------------------------------------------

    The Exchange believes that offering options on the Trust will 
benefit investors by providing them with an additional, relatively 
lower cost investing tool to gain exposure to spot ether as well as a 
hedging vehicle to meet their investment needs in connection with ether 
products and positions. Similar to other commodity ETFs in which 
options may be listed on the Exchange (e.g. SPDR[supreg] Gold Trust, 
the iShares COMEX Gold Trust, the iShares Silver Trust, or the Aberdeen 
Standard Physical Gold Trust),\11\ the proposed ETF is a trust that 
essentially offers the same objectives and benefits to investors.
---------------------------------------------------------------------------

    \11\ See Rule 4.3, Interpretation and Policy .06(a)(4).
---------------------------------------------------------------------------

    Options on the Trust will trade in the same manner as options on 
other ETFs on the Exchange. Exchange Rules that currently apply to the 
listing and trading of all options on ETFs on the Exchange, including, 
for example, Rules that govern listing criteria, expirations, exercise 
prices, minimum increments, position and exercise limits, margin 
requirements, customer accounts and trading halt procedures, will apply 
to the listing and trading of options on the Trust on the Exchange. 
Today, these rules apply to options on the various commodities ETFs 
deemed appropriate for options trading on the Exchange pursuant to Rule 
4.3, Interpretation and Policy .06.
    The Exchange's initial listing standards for ETFs on which options 
may be listed and traded on the Exchange will apply to the Trust.

[[Page 16292]]

Pursuant to Rule 4.3(a), a security (which includes a Unit) on which 
options may be listed and traded on the Exchange must be duly 
registered (with the Commission) and be an NMS stock (as defined in 
Rule 600 of Regulation NMS under the Securities Exchange Act of 1934, 
as amended (the ``Act'')), and be characterized by a substantial number 
of outstanding shares that are widely held and actively traded.\12\ 
Pursuant to Rule 4.3, Interpretation and Policy .06, requires that 
Units must either (1) meet the criteria and standards set forth in Rule 
4.3, Interpretation and Policy .01(a),\13\ or (2) be available for 
creation or redemption each business day from or through the issuer in 
cash or in kind at a price related to net asset value, and the issuer 
must be obligated to issue Units in a specified aggregate number even 
if some or all of the investment assets required to be deposited have 
not been received by the issuer, subject to the condition that the 
person obligated to deposit the investments has undertaken to deliver 
the investment assets as soon as possible and such undertaking is 
secured by the delivery and maintenance of collateral consisting of 
cash or cash equivalents satisfactory to the issuer, as provided in the 
respective prospectus. The Trust satisfies Rule 4.3, Interpretation and 
Policy .06(b)(2), as each Unit is subject to this creation and 
redemption process.
---------------------------------------------------------------------------

    \12\ The criteria and guidelines for a security to be considered 
widely held and actively traded are set forth in Rule 4.3, 
Interpretation and Policy .01, subject to exceptions.
    \13\ Rule 4.3, Interpretation and Policy .01 provides for 
guidelines to be by the Exchange when evaluating potential 
underlying securities for Exchange option transactions.
---------------------------------------------------------------------------

    Options on the Trust will be subject to the Exchange's continued 
listing standards set forth in Rule 4.4, Interpretation and Policy .06 
for Units deemed appropriate for options trading pursuant to Rule 4.3, 
Interpretation and Policy .06. Specifically, Rule 4.4, Interpretation 
and Policy .06 provides that Units that were initially approved for 
options trading pursuant to Rule 4.3, Interpretation and Policy .06 
shall be deemed not to meet the requirements for continued approval, 
and the Exchange shall not open for trading any additional series of 
option contracts of the class covering that such Units, if the Units 
cease to be an NMS stock or the Units are halted from trading in their 
primary market. Additionally, options on Units may be subject to the 
suspension of opening transactions in any of the following 
circumstances: (1) in the case of options covering Units approved for 
trading under Rule 4.3, Interpretation and Policy .06(b)(1), in 
accordance with the terms of paragraphs (a), (b), and (c) of Rule 4.4, 
Interpretation and Policy .01; (2) in the case of options covering 
Units approved for trading under Rule 4.3 Interpretation and Policy 
.06(b)(2) (as is the case for the Trust), following the initial twelve-
month period beginning upon the commencement of trading in the Units on 
a national securities exchange and are defined as an NMS stock, there 
are fewer than 50 record and/or beneficial holders of such Units for 30 
or more consecutive trading days; (3) the value of the index or 
portfolio of securities, non-U.S. currency, or portfolio of commodities 
including commodity futures contracts, options on commodity futures 
contracts, swaps, forward contracts and/or options on physical 
commodities and/or financial instruments and money market instruments 
on which the Units are based is no longer calculated or available; or 
(4) such other event shall occur or condition exist that in the opinion 
of the Exchange makes further dealing in such options on the Exchange 
inadvisable.
    Options on the Trust will be physically settled contracts with 
American-style exercise.\14\ Consistent with current Rule 4.5, which 
governs the opening of options series on a specific underlying security 
(including Units), the Exchange will open at least one expiration month 
for options on the Trust \15\ at the commencement of trading on the 
Exchange and may also list series of options on the Trust for trading 
on a weekly,\16\ monthly,\17\ or quarterly \18\ basis. The Exchange may 
also list long-term equity option series (``LEAPS'') that expire from 
12 to 180 months from the time they are listed.\19\
---------------------------------------------------------------------------

    \14\ See Rule 4.2, which provides that the rights and 
obligations of holders and writers are set forth in the Rules of the 
Options Clearing Corporation (``OCC''); and Equity Options Product 
Specifications January 3, 2024), available at Equity Options 
Specifications (cboe.com); see also OCC Rules, Chapters VIII (which 
governs exercise and assignment) and Chapter IX (which governs the 
discharge of delivery and payment obligations arising out of the 
exercise of physically settled stock option contracts).
    \15\ See Rule 4.5(b). The monthly expirations are subject to 
certain listing criteria for underlying securities described within 
Rule 4.3. Monthly listings expire the third Friday of the month. The 
term ``expiration date'' (unless separately defined elsewhere in the 
OCC By-Laws), when used in respect of an option contract (subject to 
certain exceptions), means the third Friday of the expiration month 
of such option contract, or if such Friday is a day on which the 
exchange on which such option is listed is not open for business, 
the preceding day on which such exchange is open for business. See 
OCC By-Laws Article I, Section 1. Pursuant to Rule 4.5(c), 
additional series of options of the same class may be opened for 
trading on the Exchange when the Exchange deems it necessary to 
maintain an orderly market, to meet customer demand or when the 
market price of the underlying stock moves more than five strike 
prices from the initial exercise price or prices. New series of 
options on an individual stock may be added until the beginning of 
the month in which the options contract will expire. Due to unusual 
market conditions, the Exchange, in its discretion, may add a new 
series of options on an individual stock until the close of trading 
on the business day prior to expiration.
    \16\ See Rule 4.5(d).
    \17\ See Rule 4.5(g).
    \18\ See Rule 4.5(e).
    \19\ See Rule 4.5(f).
---------------------------------------------------------------------------

    Pursuant to Rule 4.5, Interpretation and Policy .07, which governs 
strike prices of series of options on Units, the interval of strikes 
prices for series of options on the Trust will be $1 or greater when 
the strike price is $200 or less and $5 or greater where the strike 
price is over $200.\20\ Additionally, the Exchange may list series of 
options pursuant to the $1 Strike Price Interval Program,\21\ the $0.50 
Strike Program,\22\ the $2.50 Strike Price Program,\23\ and the $5 
Strike Program.\24\ Pursuant to Rule 5.4, where the price of a series 
of a Trust option is less than $3.00, the minimum increment will be 
$0.05, and where the price is $3.00 or higher, the minimum increment 
will be $0.10.\25\ Any and all new series of Trust options that the 
Exchange lists will be consistent and comply with the expirations, 
strike prices, and minimum increments set forth in Rules 4.5 and 5.4, 
as applicable.
---------------------------------------------------------------------------

    \20\ The Exchange notes that for options listed pursuant to the 
Short Term Option Series Program, the Monthly Options Series 
Program, and the Quarterly Options Series Program, Rules 4.5(d), 
(e), and (g) specifically sets forth intervals between strike prices 
on Quarterly Options Series, Short Term Option Series, and Monthly 
Options Series, respectively.
    \21\ See Rule 4.5, Interpretation and Policy .01(a).
    \22\ See Rule 4.5, Interpretation and Policy .01(b).
    \23\ See Rule 4.5, Interpretation and Policy .04.
    \24\ See Rule 4.5, Interpretation and Policy .01(f).
    \25\ If options on the Trust are eligible to participate in the 
Penny Interval Program, the minimum increment will be $0.01 for 
series with a price below $3.00 and $0.05 for series with a price at 
or above $3.00. See 5.4(d) (which describes the requirements for the 
Penny Interval Program).
---------------------------------------------------------------------------

    Trust options will trade in the same manner as any other Unit 
options on the Exchange. The Exchange Rules that currently apply to the 
listing and trading of all Unit options on the Exchange, including, for 
example, Rules that govern listing criteria, expirations, exercise 
prices, minimum increments, margin requirements, customer accounts, and 
trading halt procedures will apply to the listing and trading of Trust 
options on the Exchange in the same manner as they apply to other 
options on all other Units that are listed and traded on the Exchange, 
including the precious-metal and Bitcoin-backed

[[Page 16293]]

commodity Units already deemed appropriate for options trading on the 
Exchange pursuant to current Rule 4.3, Interpretation and Policy 
.06(a)(4).
    Rule 4.20 currently permits the Exchange to authorize for trading a 
FLEX option class on any equity security if it may authorize for 
trading a non-FLEX option class on that equity security pursuant to 
Rule 4.3. The proposed rule change amends Rule 4.20 to exclude the 
Trust from this provision.
    The Exchange also proposes to amend Rule 8.30. Specifically, the 
Exchange proposes to amend Rule 8.30, Interpretation and Policy .10 to 
provide a position limit of 25,000 same side option contracts for Trust 
options. Additionally, pursuant to the Rule 8.42, Interpretation and 
Policy .02, the exercise limits for options on the Trust will be 
equivalent to this proposed position limit. In considering the 
appropriate position and exercise limits for the Trust options, the 
Exchange reviewed the data presented by ISE in the ISE Approval. In the 
ISE Approval, ISE considered the Trust's market capitalization and 
average daily volume (``ADV'') against those of other underlying 
securities, as well as the proposed position and exercise limit in 
relation to other options. In measuring the Trust against other 
securities, ISE aggregated market capitalization and volume data for 
securities that have defined position limits utilizing data from The 
Options Clearing Corporations (``OCC'').\26\ ISE also considered the 
trading volume for the Trust in terms of daily and notional volumes 
during the period of time the Trust has been trading from July 23, 2024 
through December 14, 2024. The average daily volume for this time 
period is 5,302,533 shares and the average notional volume for this 
time period is $127,825,276.00. The Trust had 93,352 shareholders.\27\ 
ISE indicated both the average daily volume and the average notional 
volume experienced an uptick at launch (which can be typical for 
anticipated product launches) then levelled off for several months. 
Renewed growth in the cryptocurrency market caused increased growth 
beginning in early November 2024.
---------------------------------------------------------------------------

    \26\ ISE represented these computations were based on OCC data 
from October 22, 2024, and that data displaying zero values in 
market capitalization or ADV were removed.
    \27\ ISE represented it obtained this number from Broadridge 
Financial Solutions, Inc. on December 19, 2024.
---------------------------------------------------------------------------

    ISE reviewed the market capitalization and ADV of 3,930 options on 
single stock securities excluding ETFs.\28\ Next, ISE aggregated this 
data based on market capitalization and ADV and grouped option symbols 
by position limit utilizing statistical thresholds for ADV and market 
capitalization for each position limit category (i.e. 25,000, 50,000 to 
65,000, 75,000, 100,000 to less than 250,000, 250,000 to less than 
500,000, 500,000 to 1,000,000 and greater than 1,000,000). Rule 8.30 
sets out position limits for various contracts. For example, like ISE, 
a 25,000 contract limit applies to those options having an underlying 
security that does not meet the requirements for a higher options 
contract limit. ISE indicated it performed this exercise to demonstrate 
the Trust's position limit relative to other options symbols in terms 
of market capitalization and ADV. For reference the market 
capitalization for the Trust was 1.16 billion \29\ with an ADV, for the 
preceding three months prior to October 22, 2024, of greater than 2.99 
million shares. By comparison, other options symbols with similar 
market capitalization and ADV have a position limit of 50,000 contracts 
or 75,000 contracts.\30\ From a 90-day ADV perspective, ISE reviewed 
statistics that indicated that the Trust had a 90-day ADV greater than 
each of the stocks in the 100,000 contracts to 249,000 contracts range. 
Therefore, the proposed 25,000 same side position and exercise limits 
for options on the Trust are conservative.
---------------------------------------------------------------------------

    \28\ The Trust has one asset and therefore is not comparable to 
a broad based ETF where there are typically multiple components.
    \29\ ISE acquired this figure as of October 22, 2024. See 
https://www.ishares.com/us/products/337614/ishares-ethereum-trust-etf. The global supply of ether grows each day ether are minted.
    \30\ ISE determined the median market capitalization for 50,000 
contracts was 788,000,000 million and the median market 
capitalization for 75,000 contracts was 1,037,000 billion. Further, 
placing the Trust at 50,000 contracts would rank it in the 59th 
percentile in market capitalization and placing the Trust at 75,000 
contracts would rank it in the 46th percentile in market 
capitalization.
---------------------------------------------------------------------------

    Second, ISE reviewed the Trust's data relative to the market 
capitalization of the entire ether market in terms of exercise risk and 
availability of deliverables. Utilizing data as of October 22, 2024, 
there were 120,392,960 Ethereum in circulation. The price of Ethereum 
on October 22, 2024, was $2,620 per coin which equates to a market 
capitalization of greater than $315 billion US dollars. If a position 
limit of 25,000 options were considered (the position limit that would 
be typically assigned based upon data), the exercisable risk would 
represent less than 4.3524% of the outstanding shares of the Trust.\31\ 
Since the Trust has a creation and redemption process managed through 
the issuer, we can additionally compare the position limit sought to 
the total market capitalization of the entire Ethereum market. In this 
case, the exercisable risk represented by 25,000 options on the Trust 
would be less than 0.03% of the market capitalization of all 
outstanding ether. Assuming a scenario where all 25,000 options on 
ether shares were exercised given the proposed 25,000 per same side 
position limit, this would have a virtually unnoticed impact on the 
entire ether market. This analysis demonstrates that the proposed 
25,000 per same side position limit (and exercise limit) is 
conservative and appropriate for options on the Trust.
---------------------------------------------------------------------------

    \31\ The 4.4% was calculated as follows: 2,500,000 (exercisable 
stock from position limit)/57,440,000 (shares outstanding on October 
22, 2024) = 4.35237%.
---------------------------------------------------------------------------

    Third, ISE reviewed the proposed position limit by comparing it to 
position limits for derivative products regulated by the Commodity 
Futures Trading Commission (``CFTC''). While the CFTC, through the 
relevant Designated Contract Markets, only regulates options positions 
based upon delta equivalents (creating a less stringent standard), we 
examined equivalent ether futures position limits. In particular, ISE 
looked at the CME Ethereum futures contract \32\ that has a position 
limit of 8,000 futures.\33\ On October 22, 2024, CME ether futures 
settled at $2,629. Using a contract multiplier of $50, a position limit 
of 8,000 futures would have a notional value $1.0516 billion (8,000 x 
$50 x $2,629). Using an October 22, 2024, share price of $19.91 for 
shares of the Trust, a futures position of 8,000 contracts, with a 
notional value of $1.0516 billion dollars would equate to an options 
position of 528,176 contracts ($1.0516 billion (notional value of 8,000 
Ethereum futures contracts)/$19.91 (price of the Trust shares) = 
52,817,679 (Trust shares)/100 (the number of shares represented by one 
options contract)) = 528,176 options contracts. Because substantial 
sums of any distributed options portfolio are likely to be out of the 
money on expiration, an options position limit equivalent to the CME 
position limit for Ethereum (considering that all options deltas are 
<=1.00) should be a bit higher than the CME implied 528,176 contract 
limit.
---------------------------------------------------------------------------

    \32\ CME Ether Futures are described in Chapter 350 of CME's 
Rulebook.
    \33\ See CME Rulebook, Chapter 5, Position Limit, Position 
Accountability and Reportable Level Table in the Interpretations & 
Special Notices.
---------------------------------------------------------------------------

    The Exchange notes, unlike options contracts, CME position limits 
are calculated on a net futures-equivalent basis by contract and 
include contracts

[[Page 16294]]

that aggregate into one or more base contracts according to an 
aggregation ratio(s).\34\ Therefore, if a portfolio includes positions 
in options on futures, CME would aggregate those positions into the 
underlying futures contracts in accordance with a table published by 
CME on a delta equivalent value for the relevant spot month, subsequent 
spot month, single month and all month position limits.\35\ If a 
position exceeds position limits because of an option assignment, CME 
permits market participants to liquidate the excess position within one 
business day without being considered in violation of its rules. 
Additionally, if at the close of trading, a position that includes 
options exceeds position limits for futures contracts, when evaluated 
using the delta factors as of that day's close of trading but does not 
exceed the limits when evaluated using the previous day's delta 
factors, then the position shall not constitute a position limit 
violation. Considering CME's position limits on futures for Ethereum, 
the Exchange believes that that the proposed same side position limits 
are more than appropriate for the Trust options.
---------------------------------------------------------------------------

    \34\ See CME Rulebook Chapter 5, Position Limit, Position 
Accountability and Reportable Level Table in the Interpretations & 
Special Notices.
    \35\ Id.
---------------------------------------------------------------------------

    In analyzing the proposed position limit for options on the Trust, 
ISE also considered the supply of ether. Specifically, ISE examined the 
number of market participants with a position limit of 25,000 contracts 
that would need to exercise in unison to put the underlying asset under 
stress. In the case of options on ether, the proposed 25,000 same side 
position and exercise limit effectively restricts a market participant 
from holding positions that could be exercised in excess of 2,500,000 
shares of the Trust. Utilizing data from October 22, 2024, the Trust 
had 57,440,000 shares outstanding, therefore 22.976 participants would 
have to simultaneously exercise their position limits in order to 
create a scenario that may put the underlying asset (shares of the 
Trust) under stress. The Exchange notes that historically, from 
observation only, it appears that no more than five market participants 
holding options positions in any single security have exercised in 
unison in any option. As unlikely an occurrence as all market 
participants exercising their positions in unison would be, if it were 
to occur, it should be noted that even such an occurrence would not 
likely put the Trust under stress as economic incentives, would induce 
the creation of more shares through the ETF creation and redemption 
process.
    Further, given that the current global supply of Ethereum, the 
underlying asset of the Trust, is 120,392,960 \36\ coins and each 
Ethereum coin can currently be exchanged (Ethereum to USD and then USD 
to Trust shares) for 131.6 shares of the Trust another 15,843,979,598 
shares of the Trust could be created by the underlying ETF. In 
addition, as of October 22, 2024, a 25,000 contract position limit for 
options on the Trust would represent less than 4.3524% of the 
outstanding shares of the Trust (2,500,000 (position limit exercise)/
57,440,000 (shares outstanding of the Trust on October 22, 2024)) = 
4.3524%.\37\ Also, as of October 22, 2024, a 25,000 contract position 
limit for options on the Trust would represent less than .01578% of the 
global supply of ether (2,500,000 (position limit exercise)/120,392,960 
(number of ether) x 131.6 (Trust shares per ether)) = .01578%.
---------------------------------------------------------------------------

    \36\ This figure was acquired as of October 22, 2024. See 
https://www.ishares.com/us/products/337614/ishares-ethereum-trust-etf. The global supply of ether grows each day ether are minted.
    \37\ See https://coinmarketcap.com/currencies/ethereum/.
---------------------------------------------------------------------------

    Today, the Exchange has an adequate surveillance program in place 
for options. Cboe intends to apply those same program procedures to 
options on the Trust that it applies to the Exchange's other options 
products, including options on Units.\38\ Cboe's market surveillance 
staff would have access to the surveillances conducted by Cboe BYX 
Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., and 
Cboe EDGX Exchange, Inc.\39\ with respect to the Trust and would review 
activity in the underlying Trust when conducting surveillances for 
market abuse or manipulation in the options on the Trust. Additionally, 
the Exchange is a member of the Intermarket Surveillance Group 
(``ISG'') under the Intermarket Surveillance Group Agreement. ISG 
members work together to coordinate surveillance and investigative 
information sharing in the stock, options, and futures markets. In 
addition to obtaining information from its affiliated markets, the 
Exchange would be able to obtain information regarding trading in 
shares of the Trust from their primary listing markets and from other 
markets that trade shares of the Trust through ISG. In addition, Cboe 
has a Regulatory Services Agreement with the Financial Industry 
Regulatory Authority (``FINRA'') for certain market surveillance, 
investigation and examinations functions. Pursuant to a multi-party 
17d-2 joint plan, all options exchanges allocate amongst themselves and 
FINRA responsibilities to conduct certain options-related market 
surveillance that are common to rules of all options exchanges.\40\
---------------------------------------------------------------------------

    \38\ The surveillance program includes surveillance patterns for 
price and volume movements as well as patterns for potential 
manipulation (e.g., spoofing and marking the close).
    \39\ Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA 
Exchange, Inc., and Cboe EDGX Exchange, Inc. are affiliated markets 
of the Exchange.
    \40\ Section 19(g)(1) of the Act, among other things, requires 
every self-regulatory organization (``SRO'') registered as a 
national securities exchange or national securities association to 
comply with the Act, the rules and regulations thereunder, and the 
SRO's own rules, and, absent reasonable justification or excuse, 
enforce compliance by its members and persons associated with its 
members. See 15 U.S.C. 78q(d)(1) and 17 CFR 240.17d-2. Section 
17(d)(1) of the Act allows the Commission to relieve an SRO of 
certain responsibilities with respect to members of the SRO who are 
also members of another SRO (``common members''). Specifically, 
Section 17(d)(1) allows the Commission to relieve an SRO of its 
responsibilities to: (i) receive regulatory reports from such 
members; (ii) examine such members for compliance with the Act and 
the rules and regulations thereunder, and the rules of the SRO; or 
(iii) carry out other specified regulatory responsibilities with 
respect to such members.
---------------------------------------------------------------------------

    The underlying shares of spot Ethereum ETPs, including the Trust, 
are also subject to safeguards related to addressing market abuse and 
manipulation. As the Commission stated in its order approving proposals 
of several exchanges to list and trade shares of spot Ethereum-based 
ETPs,\41\ ``[e]ach Exchange has a comprehensive surveillance-sharing 
agreement with the [CME] via their common membership in ISG. This 
facilitates the sharing of information that is available to the CME 
through its surveillance of its markets, including its surveillance of 
the CME Ether futures market.'' \42\ The Exchange states that, given 
the consistently high correlation between the CME Ethereum futures 
market and the spot Ethereum market, as confirmed by the Commission 
through robust correlation analysis, the Commission was able to 
conclude that such surveillance sharing agreements could reasonably be 
``expected to assist in surveilling for fraudulent and manipulative 
acts and practices in the specific context of the

[[Page 16295]]

[Ethereum ETPs].'' \43\ In light of surveillance measures related to 
both options and futures as well as the underlying Trust,\44\ the 
Exchange believes that existing surveillance procedures are designed to 
deter and detect possible manipulative behavior which might potentially 
arise from listing and trading the proposed options on the Trust. 
Further, the Exchange will implement any new surveillance procedures it 
deems necessary to effectively monitor the trading of options on the 
Trust.
---------------------------------------------------------------------------

    \41\ See Securities Exchange Act Release Nos. 100224 (May 23, 
2024), 89 FR 46937 (May 30, 2024) (SR-NYSEArca-2023-70; SR-NYSEArca-
2024-31; SR-NASDAQ-2023-045; SR-CboeBZX-2023-069; SR-CboeBZX-2023-
070; SR-CboeBZX-2023-087; SR-CboeBZX-2023-095; and SR-CboeBZX-2024-
018) (Order Granting Accelerated Approval of Proposed Rule Changes, 
as Modified by Amendments Thereto, to List and Trade Shares of 
Ether-Based Exchange-Traded Products) (``Ethereum ETP Approval 
Order'').
    \42\ See Ethereum ETP Approval Order, at 46938 (footnotes 
excluded).
    \43\ See Ethereum ETP Approval Order, at 46941 (footnote 
excluded).
    \44\ See Ethereum ETP Approval Order.
---------------------------------------------------------------------------

    Finally, quotation and last sale information for ETFs is available 
via the Consolidated Tape Association (``CTA'') high speed line. 
Quotation and last sale information for such securities is also 
available from the exchange on which such securities are listed. 
Quotation and last sale information for options on the Trust will be 
available via Options Price Reporting Authority (``OPRA'') and major 
market data vendors. The Exchange has also analyzed its capacity and 
represents that it believes the Exchange and OPRA have the necessary 
systems capacity to handle the additional traffic associated with the 
listing of new series that may result from the introduction of options 
on the Trust up to the number of expirations currently permissible 
under the Rules.
    The Exchange believes that offering options on the Trust will 
benefit investors by providing them with an additional, relatively 
lower cost investing tool to gain exposure to the price of Ethereum and 
hedging vehicle to meet their investment needs in connection with 
Ethereum -related products and positions. The Exchange expects 
investors will transact in options on the Trust in the unregulated 
over-the-counter (``OTC'') options market,\45\ but may prefer to trade 
such options in a listed environment to receive the benefits of trading 
listing options, including (1) enhanced efficiency in initiating and 
closing out positions; (2) increased market transparency; and (3) 
heightened contra-party creditworthiness due to the role of OCC as 
issuer and guarantor of all listed options. The Exchange believes that 
listing Trust options may cause investors to bring this liquidity to 
the Exchange, would increase market transparency and enhance the 
process of price discovery conducted on the Exchange through increased 
order flow. The Units that hold financial instruments, money market 
instruments, precious metal commodities, or Bitcoin on which the 
Exchange may already list and trade options are trusts structured in 
substantially the same manner as the Trust and essentially offer the 
same objectives and benefits to investors, just with respect to 
different assets. The Exchange notes that it has not identified any 
issues with the continued listing and trading of any Unit options, 
including Units that hold commodities (i.e., precious metals and 
Bitcoin) that it currently lists and trades on the Exchange.
---------------------------------------------------------------------------

    \45\ The Exchange understands from customers that investors have 
historically transacted in options on Units in the OTC options 
market if such options were not available for trading in a listed 
environment.
---------------------------------------------------------------------------

    Finally, the Exchange notes that applicable Exchange rules will 
require that customers receive appropriate disclosure before trading 
options in the Trust.\46\ Further, brokers opening accounts and 
recommending options transactions must comply with relevant customer 
suitability standards.\47\
---------------------------------------------------------------------------

    \46\ See Rules 9.1(b) and (e).
    \47\ See Rule 9.3.
---------------------------------------------------------------------------

2. Statutory Basis
    The Exchange believes the proposed rule change is consistent with 
the Act and the rules and regulations thereunder applicable to the 
Exchange and, in particular, the requirements of Section 6(b) of the 
Act.\48\ Specifically, the Exchange believes the proposed rule change 
is consistent with the Section 6(b)(5) \49\ 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) \50\ requirement that the rules of 
an exchange not be designed to permit unfair discrimination between 
customers, issuers, brokers, or dealers.
---------------------------------------------------------------------------

    \48\ 15 U.S.C. 78f(b).
    \49\ 15 U.S.C. 78f(b)(5).
    \50\ Id.
---------------------------------------------------------------------------

    In particular, the Exchange believes that the proposal to list and 
trade options on the Trust will remove impediments to and perfect the 
mechanism of a free and open market and a national market system and, 
in general, protect investors because offering options on the Trust 
will provide investors with a greater opportunity to realize the 
benefits of utilizing options on an ETF based on spot Ethereum, 
including cost efficiencies and increased hedging strategies. The 
Exchange believes that offering options on a competitively priced ETF 
based on spot Ethereum will benefit investors by providing them with an 
additional, relatively lower-cost risk management tool, allowing them 
to manage, more easily, their positions and associated risks in their 
portfolios in connection with exposure to spot Ethereum. Additionally, 
the Exchange's offering of Trust options will provide investors with 
the ability to transact in such options in a listed market environment 
as opposed to in the unregulated OTC options market, which would 
increase market transparency and enhance the process of price discovery 
conducted on the Exchange through increased order flow to the benefit 
of all investors. Today, the Exchange lists options on other commodity 
(including Ethereum) ETFs structured as a trust, which essentially 
offer the same objectives and benefits to investors, and for which the 
Exchange has not identified any issues with the continued listing and 
trading of options on those ETFs.
    The Exchange also believes the proposal to permit options on the 
Trust will remove impediments to and perfect the mechanism of a free 
and open market and a national market system, because options on the 
Trust will comply with current Exchange Rules. Options on the Trust 
must satisfy the initial listing standards and continued listing 
standards currently in the Rules, applicable to options on all ETFs, 
including options on other commodity ETFs already deemed appropriate 
for options trading on the Exchange pursuant to Rule 4.3, 
Interpretation and Policy .06(a)(d). Additionally, as demonstrated 
above, the Trust is characterized by a substantial number of shares 
that are widely held and actively traded. Further, Rules that currently 
govern the listing and trading of options on ETFs, including 
permissible expirations, strike prices, minimum increments, position 
and exercise limits (as proposed herein), and margin requirements, will 
govern the listing and trading of options on the Trust.
    The Exchange believes the proposed position and exercise limits are 
designed to prevent fraudulent and manipulative acts and practices and 
promote just and equitable principles of trade, as they are designed to 
address potential manipulative schemes and adverse market impacts 
surrounding the use of options, such as disrupting the

[[Page 16296]]

market in the security underlying the options. The proposed position 
and exercise limits for options on each of the Trust are 25,000 
contracts. These position and exercise limits are the lowest position 
and exercise limits available in the options industry, are extremely 
conservative and more than appropriate given the Trust's market 
capitalization, ADV, and high number of outstanding shares. The 
proposed position limit, and exercise limit, is consistent with the Act 
as it addresses concerns related to manipulation and protection of 
investors because, as demonstrated above, the position limit (and 
exercise limit) is extremely conservative and more than appropriate 
given the Trust is actively traded. In support of the proposed position 
and exercise limits for options on the Trust are 25,000 contracts, the 
Exchange is citing the in depth analysis ISE did in the ISE Approval. 
As noted above, in ISE Approval, ISE considered the: (1) Trust's market 
capitalization and ADV, and proposed position limit in relation to 
other securities; (2) market capitalization of the entire Ethereum 
market in terms of exercise risk and availability of deliverables; (3) 
proposed position limit by comparing it to position limits for 
derivative products regulated by the CFTC; and (4) supply of Ethereum. 
Based on the Exchange's review of these analyses, the Exchange believes 
that setting position and exercise limits for options on the Trust at 
25,000 contracts is more than appropriate. The proposed position and 
exercise limits reasonably and appropriately balance the liquidity 
provisioning in the market against the prevention of manipulation. The 
Exchange believes these proposed limits are effectively designed to 
prevent an individual customer or entity from establishing options 
positions that could be used to manipulate the market of the underlying 
as well as the Ethereum market.\51\
---------------------------------------------------------------------------

    \51\ See Securities Exchange Act Release No. 39489 (December 24, 
1997), 63 FR 276 (January 5, 1998) (SR-CBOE-1997-11).
---------------------------------------------------------------------------

    The Exchange represents that it has the necessary systems capacity 
to support the new Trust options. As discussed above, the Exchange 
believes that its existing surveillance and reporting safeguards are 
designed to deter and detect possible manipulative behavior which might 
arise from listing and trading Unit options, including Trust options. 
The Exchange's existing surveillance and reporting safeguards are 
designed to deter and detect possible manipulative behavior which might 
arise from listing and trading options on ETFs and ETPs, such as 
(existing) precious metal-commodity backed ETP options as well as the 
proposed options on the Trust. The Exchange believes that its 
surveillance procedures are adequate to properly monitor the trading of 
options on the Trust in all trading sessions and to deter and detect 
violations of Exchange rules. Specifically, the Exchange's market 
surveillance staff will have access to surveillances that it conducts, 
and that FINRA conducts on its behalf, with respect to the Trust and, 
as appropriate, would review activity in the underlying Fund when 
conducting surveillances for market abuse or manipulation in the 
options on the Trust. Additionally, the Exchange is a member of the ISG 
under the Intermarket Surveillance Group Agreement. ISG members work 
together to coordinate surveillance and investigative information 
sharing in the stock, options, and futures markets. In addition, the 
Exchange has a Regulatory Services Agreement with the FINRA and as 
noted herein, pursuant to a multi-party 17d-2 joint plan, all options 
exchanges allocate regulatory responsibilities to FINRA to conduct 
certain options-related market surveillances. Further, the Exchange 
will implement any new surveillance procedures it deems necessary to 
effectively monitor the trading of options on the Trust.
    The underlying shares of spot Ethereum ETPs, including the Trust, 
are also subject to safeguards related to addressing market abuse and 
manipulation. As the Commission stated in its order approving proposals 
of several exchanges to list and trade shares of spot Ethereum-based 
ETPs, ``[e]ach Exchange has a comprehensive surveillance-sharing 
agreement with the CME via their common membership in the Intermarket 
Surveillance Group. This facilitates the sharing of information that is 
available to the CME through its surveillance of its markets, including 
its surveillance of the CME ether futures market.'' \52\ The Exchange 
states that, given the consistently high correlation between the CME 
Ethereum futures market and the spot Ethereum market, as confirmed by 
the Commission through robust correlation analysis, the Commission was 
able to conclude that such surveillance sharing agreements could 
reasonably be ``expected to assist in surveilling for fraudulent and 
manipulative acts and practices in the specific context of the [Ether 
ETPs].'' \53\ In light of the foregoing, the Exchange believes that 
existing surveillance procedures are designed to deter and detect 
possible manipulative behavior which might potentially arise from 
listing and trading the proposed options on the Trust. Further, the 
Exchange will implement any new surveillance procedures it deems 
necessary to effectively monitor the trading of options on Ethereum 
ETPs.
---------------------------------------------------------------------------

    \52\ See Ethereum ETP Approval Order, 89 FR, at 46938.
    \53\ See Ethereum ETP Approval Order, 89 FR at 46941.
---------------------------------------------------------------------------

    The Exchange believes the proposed rule change to exclude the Trust 
from being eligible for trading as FLEX options is consistent with the 
Act, because it will permit the Exchange to continue to participate in 
ongoing discussions with the Commission regarding appropriate position 
limits for ETF options.\54\
---------------------------------------------------------------------------

    \54\ The Exchange will submit a separate rule filing that would 
permit the Exchange to authorize for trading FLEX options on the 
Trust (which filing may propose changes to existing FLEX option 
position limits for such options if appropriate).
---------------------------------------------------------------------------

    Finally, the Exchange notes that this proposal will remove 
impediments to and perfect the mechanism of a free and open market and 
a national market system and, in general, protect investors because 
applicable Exchange rules will require that customers receive 
appropriate disclosure before trading options in the Trust \55\ and 
will require that brokers opening accounts and recommending options 
transactions must comply with relevant customer suitability 
standards.\56\
---------------------------------------------------------------------------

    \55\ See Rules 9.1(b) and (e).
    \56\ See Rule 9.3.
---------------------------------------------------------------------------

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 that the proposed rule change will impose any burden on 
intramarket competition that is not necessary or appropriate in 
furtherance of the purposes of the Act as Trust options will be equally 
available to all market participants who wish to trade such options and 
will trade generally in the same manner as other options. The Rules 
that currently apply to the listing and trading of all Unit options on 
the Exchange, including, for example, Rules that govern listing 
criteria, expirations, exercise prices, minimum increments, margin 
requirements, customer accounts, and trading halt procedures will apply 
to the listing and trading of

[[Page 16297]]

the Trust options on the Exchange in the same manner as they apply to 
other options on all other Units that are listed and traded on the 
Exchange. Also, and as stated above, the Exchange already lists options 
on other commodity-based Units (including Bitcoin-based).\57\ Further, 
the Trust would need to satisfy the maintenance listing standards set 
forth in the Exchange Rules in the same manner as any other Unit for 
the Exchange to continue listing options on them.
---------------------------------------------------------------------------

    \57\ See Rule 4.3, Interpretation and Policy .06(a)(4).
---------------------------------------------------------------------------

    The Exchange does not believe that the proposal to list and trade 
options on the Trust will impose any burden on intermarket competition 
that is not necessary or appropriate in furtherance of the purposes of 
the Act. To the extent that the advent of the Trust options trading on 
the Exchange may make the Exchange a more attractive marketplace to 
market participants at other exchanges, such market participants are 
free to elect to become market participants on the Exchange. The 
Exchange notes that listing and trading Trust options on the Exchange 
will subject such options to transparent exchange-based rules as well 
as price discovery and liquidity, as opposed to alternatively trading 
such options in the OTC market.
    The Exchange believes that the proposed rule change may relieve any 
burden on, or otherwise promote, competition, as it is designed to 
increase competition for order flow on the Exchange in a manner that is 
beneficial to investors by providing them with a lower-cost option to 
hedge their investment portfolios. The Exchange notes that it operates 
in a highly competitive market in which market participants can readily 
direct order flow to competing venues that offer similar products. 
Ultimately, the Exchange believes that offering Trust options for 
trading on the Exchange will promote competition by providing investors 
with an additional, relatively low-cost means to hedge their portfolios 
and meet their investment needs in connection with Ethereum prices and 
Ethereum-related products and positions on a listed options exchange.

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

    The Exchange has filed the proposed rule change pursuant to Section 
19(b)(3)(A) of the Act \58\ and Rule 19b-4(f)(6) thereunder.\59\ 
Because the foregoing proposed rule change does not: (i) significantly 
affect the protection of investors or the public interest; (ii) impose 
any significant burden on competition; and (iii) become operative for 
30 days from the date on which it was filed, or such shorter time as 
the Commission may designate, it has become effective pursuant to 
Section 19(b)(3)(A)(iii) of the Act \60\ and subparagraph (f)(6) of 
Rule 19b-4 thereunder.\61\
---------------------------------------------------------------------------

    \58\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \59\ 17 CFR 240.19b-4(f)(6).
    \60\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \61\ 17 CFR 240.19b-4(f)(6). In addition, Rule 19b-4(f)(6) 
requires a self-regulatory organization to give the Commission 
written notice of its intent to file the proposed rule change at 
least five business days prior to the date of filing of the proposed 
rule change, or such shorter time as designated by the Commission. 
The Commission has waived the pre-filing requirement.
---------------------------------------------------------------------------

    A proposed rule change filed under Rule 19b-4(f)(6) \62\ under the 
Act does not normally become operative prior to 30 days after the date 
of the filing. However, pursuant to Rule 19b-4(f)(6)(iii),\63\ the 
Commission may designate a shorter time if such action is consistent 
with the protection of investors and the public interest. The Exchange 
has requested that the Commission waive the 30-day operative delay so 
that the proposal may become operative immediately upon filing. The 
Commission previously approved the listing of options on the iShares 
Ethereum Trust.\64\ The Exchange has provided information regarding the 
underlying iShares Ethereum Trust, including, among other things, 
information regarding trading volume, the number of shareholders, and 
the market capitalization of the iShares Ethereum Trust. The proposal 
also establishes position and exercise limits for options on the 
iShares Ethereum Trust and provides information regarding the 
surveillance procedures that will apply to iShares Ethereum Trust 
options. The Commission believes that waiver of the operative delay 
could benefit investors by providing an additional venue for trading 
iShares Ethereum Trust options. Therefore, the Commission believes that 
waiver of the 30-day operative delay is consistent with the protection 
of investors and the public interest. Accordingly, the Commission 
hereby waives the 30-day operative delay and designates the proposed 
rule change as operative upon filing.\65\
---------------------------------------------------------------------------

    \62\ 17 CFR 240.19b-4(f)(6).
    \63\ 17 CFR 240.19b-4(f)(6)(iii).
    \64\ See ISE Approval, supra note 6.
    \65\ For purposes only of waiving the 30-day operative delay, 
the Commission has also considered the proposed rule's impact on 
efficiency, competition, and capital formation. See 15 U.S.C. 
78c(f).
---------------------------------------------------------------------------

    At any time within 60 days of the filing of the proposed rule 
change, the Commission summarily may temporarily suspend such rule 
change if it appears to the Commission that such action is necessary or 
appropriate in the public interest, for the protection of investors, or 
otherwise in furtherance of the purposes of the Act. If the Commission 
takes such action, the Commission will institute proceedings to 
determine whether the proposed rule change should be approved or 
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 (https://www.sec.gov/rules/sro.shtml); or
     Send an email to [email protected]. Please include 
file number SR-CBOE-2025-025 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-2025-025. 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 (https://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

[[Page 16298]]

printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549, on official business days between the hours of 10 
a.m. and 3 p.m. Copies of the filing also will be available for 
inspection and copying at the principal office of the Exchange. Do not 
include personal identifiable information in submissions; you should 
submit only information that you wish to make available publicly. We 
may redact in part or withhold entirely from publication submitted 
material that is obscene or subject to copyright protection. All 
submissions should refer to file number SR-CBOE-2025-025 and should be 
submitted on or before May 8, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\66\
---------------------------------------------------------------------------

    \66\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-06509 Filed 4-16-25; 8:45 am]
BILLING CODE 8011-01-P