[Federal Register Volume 91, Number 144 (Wednesday, July 29, 2026)]
[Notices]
[Pages 47886-47894]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-15252]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-105983; File No. SR-CboeEDGX-2026-049]


Self-Regulatory Organizations; Cboe EDGX Exchange, Inc.; Notice 
of Filing and Immediate Effectiveness of a Proposed Rule Change To 
Introduce a Data Vendor Program

July 24, 2026.
    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 July 15, 2026, Cboe EDGX Exchange, Inc. (the ``Exchange'' or ``EDGX) 
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 EDGX Exchange, Inc. (the ``Exchange'' or ``EDGX'') proposes to 
introduce a Data Vendor Program, which includes introducing a new 
defined term of Data Vendor, along with other clarifying changes. The 
text of the proposed rule change is provided in Exhibit 5.
    The text of the proposed rule change is also available on the 
Commission's website (https://www.sec.gov/rules/sro.shtml), the 
Exchange's website (https://www.cboe.com/us/equities/regulation/rule_filings/edgx/), and at the principal office of the Exchange.

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 purpose of this proposed rule change is to (i) introduce a 
definition of Data Vendor; (ii) codify the existing definition (as 
defined in the Exchange's applicable North American Market Data 
Policies) of Extranet Service Provider; (iii) codify an existing 
practice that permits an External Distributor of both Cboe One Summary 
and Cboe One Premium to be liable only for the External Distribution 
Fee for Cboe One Premium; and (iv) create a program for Data Vendors in 
order to incentivize Data Vendors to build out the applicable feeds and 
make them commercially available to subscribers.\3\ The proposed 
program will provide fee waivers (as described below) for External 
Distribution Fees for Data Vendors for the Cboe One Summary Feed, Cboe 
One Premium Feed, EDGX Summary Depth Data Feed, and EDGX Top Data Feed.
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    \3\ The Exchange initially submitted the proposed rule change on 
July 1, 2026 (SR-CboeEDGX-2026-048). On July 15, 2026, the Exchange 
withdrew that filing and submitted this filing.

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[[Page 47887]]

Proposed Definitions
    In connection with this proposed program, the Exchange first 
proposes to adopt a definition for a specific category of participants. 
Specifically, the Exchange proposes to establish the term ``Data 
Vendor'' to mean ``an External Distributor that (i) is actively 
engaged, as part of its primary business objective, in the solicitation 
of unaffiliated third-party Distributors to redistribute a transformed 
Market Data Product; (ii) does not maintain a brokerage relationship 
with Users in connection with the receipt or use of the applicable 
Market Data Product; and (iii) is not an Extranet Service Provider.'' 
As part of this new definition, and as further described below, the 
Exchange proposes to codify the existing definition of Extranet Service 
Provider within the Cboe Global North American Market Data Policies to 
be within its Fee Schedule.
    The Exchange has also established objective, verifiable criteria 
for determining eligibility as a Data Vendor. The following criteria, 
which will be reflected in the Exchange's Fee Schedule, must be 
satisfied: (1) the External Distributor must identify itself as a Data 
Vendor in publicly available marketing materials; (2) the External 
Distributor must transform the applicable Market Data Product before 
redistribution, which may include aggregation across multiple data 
sources, normalization into a consistent format, enrichment with 
reference data or analytics, or repackaging into a proprietary delivery 
mechanism (e.g., terminal, API, or proprietary feed); (3) the External 
Distributor must redistribute the applicable transformed Market Data 
Product to downstream Distributors as part of a paid commercial 
offering; (4) the External Distributor must not maintain a brokerage 
relationship with any User to whom it distributes the applicable Market 
Data Product; (5) the External Distributor must not be an Extranet 
Service Provider; and (6) the External Distributor must be actively 
engaged in the solicitation of unaffiliated third-party Distributors to 
subscribe to and redistribute the applicable transformed Market Data 
Product. Upon request, the External Distributor must provide a written 
attestation certifying compliance with the foregoing criteria. The 
Exchange may request supporting documentation, including but not 
limited to Distributor subscriber lists, revenue breakdowns by 
recipient type, and descriptions of the transformations applied to the 
Market Data Product. These objective eligibility criteria ensure that 
the Data Vendor Program is equitably applied to all similarly situated 
market participants.
External Distributor
    To begin, ``Data Vendor'' is intended to only encompass External 
Distributors and not Internal Distributors. An External Distributor is 
defined as a Distributor that receives the Exchange Market Data product 
and then distributes that data to a third party or one or more Users 
outside the Distributor's own entity.\4\ The Exchange seeks to adopt 
this program in order to encourage broader redistribution of this data. 
As such, the Exchange limits this to External Distributors as the 
intent of this program is to have data distributed outside one's own 
entity.
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    \4\ See EDGX Equities Fee Schedule.
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Primary Business Is To Redistribute to Distributors
    To be eligible as a Data Vendor, an External Distributor must be 
taking in data for the primary business purpose of selling access to 
the applicable feed as a service in its own right, not merely 
redistributing data in incidental support of broader business functions 
such as trade execution, account management, or brokerage services. The 
Exchange notes that, as part of its business, a Data Vendor may 
redistribute a market data product to Users, but the primary purpose 
must be to redistribute data to Distributors. The Exchange will assess 
whether an External Distributor's primary business purpose satisfies 
this criterion based on the External Distributor's publicly available 
marketing materials. If the Exchange were to modify this requirement to 
permit a primary business purpose of redistribution to either 
Distributors or Users, it would unintentionally include firms that may 
redistribute only to Users and that are not traditionally considered 
data vendors (e.g., a media outlet or a bank).
Transformed Market Data Product
    To be eligible, the Exchange requires that the Data Vendor not 
simply pass through data in its original form. Transformation may 
include aggregation across multiple sources, normalization into a 
consistent format, enrichment with derived analytics, or repackaging 
into a proprietary delivery mechanism (e.g., terminal, API, feed), or 
any other value-added processing that distinguishes the output from the 
original source data.
No Brokerage Relationship With Users
    Next, the Exchange proposes that the definition of Data Vendor 
include a stipulation that a Data Vendor must not maintain a brokerage 
relationship with Users who receive the market data product. The 
Exchange already has programs aimed at retail brokers, for example, 
both the Small Retail Broker Program and the Small Retail Broker Hosted 
Solutions Program.\5\ This proposed program is intended to encourage 
Data Vendors specifically to take in the applicable feeds and 
distribute them. A Data Vendor's service model is different from a 
retail broker's, as a Data Vendor's business model is built around 
providing data to firms and Users alike, whereas a retail broker's 
business model is focused on connecting Users to markets in order to 
trade and may include providing market data as part of its offering to 
its Users. As the Exchange already has programs specifically for retail 
brokers, the Exchange does not believe it would be appropriate to 
include retail brokers here. The Exchange notes that if a Data Vendor 
that is currently receiving a fee waiver under this Program 
subsequently commences a brokerage relationship with its Users, it will 
no longer satisfy the definition of Data Vendor and will cease to be 
eligible for the Program. In such case, the External Distributor would 
be assessed the standard External Distribution Fee for the applicable 
feed as of the date it no longer satisfies the definition of Data 
Vendor.
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    \5\ See EDGX Equities Fee Schedule.
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Not an Extranet Service Provider
    As noted above, the Exchange proposes also to define Extranet 
Service Provider when it introduces the definition of Data Vendor into 
its Fee Schedule. Today, this term already exists in the Cboe Global 
Markets North American Data Policies.\6\ The Exchange proposes to 
codify this definition in its Fee Schedule because the proposed 
definition of Data Vendor directly references this defined term. 
Specifically, the Exchange proposes to codify that an Extranet Service 
Provider is ``an entity that has entered into a Cboe Global Markets 
Global Data Agreement and Transmits an Exchange Market Data Product, 
via an extranet operated by such entity, to data recipients. `Transmit' 
means to direct an Exchange Market Data Product to one or more data 
recipients without modification of the content, format, or other 
characteristics of the Exchange Market Data Product.'' An Extranet

[[Page 47888]]

Service Provider is not authorized to use or process an Exchange Market 
Data Product for any purpose.
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    \6\ See Market_Data_Policies.pdf.
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Applicable Data Feeds
    By way of background, the Exchange offers the Cboe One Premium Data 
Feed, which is a data feed that disseminates, on a real-time basis, the 
aggregate best bid and offer (``BBO'') of all displayed orders for 
securities traded on the Exchange and its affiliated equities exchanges 
and enables recipients to receive aggregated two-sided quotations from 
EDGX and its affiliated equities exchanges for up to twelve (12) price 
levels (and, for a limited time, up to five (5) price levels).\7\ The 
Cboe One Premium Data Feed is created using the data from the Exchange 
and each of its affiliated equities exchanges' Summary Depth data feeds 
(allowing for up to 48 total price levels).
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    \7\ EDGX filed to increase the levels of the Cboe One Premium 
Data Feed from five (5) levels to twelve (12) levels. To help in 
this transition, it is currently supporting both the five and twelve 
level feeds; however, as stated in its rule, EDGX shall sunset the 
five (5) level feed of Cboe One Premium by December 31, 2026 (with 
the date to be announced via Exchange Notice). See Rule 13.8(b)(i).
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    The Exchange also offers the Cboe One Summary Data Feed, which 
disseminates, on a real-time basis, the aggregate BBO of all displayed 
orders for securities traded on EDGX and its affiliated equities 
exchanges and also contains individual last sale information for EDGX 
and its affiliated equities exchanges.\8\
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    \8\ The Cboe One Summary Feed is distinguishable from the Cboe 
One Premium Feed in that it does not provide depth of book data. In 
contrast, the Cboe One Premium Feed contains all the available data 
in the Cboe One Summary Feed and also provides depth of book data.
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    The Exchange offers the EDGX Summary Depth Data Feed, which is a 
data feed that offers aggregated two-sided quotations up to twelve 
price levels for all displayed orders entered into the System and the 
EDGX Top Data Feed, which is a data feed that offers top-of-book 
quotations and last sale information based on orders entered into the 
Exchange's System.
External Distribution Fees for Cboe One Premium and Cboe One Summary
    The proposed rule change also clarifies that External Distributors 
of both Cboe One Summary and Cboe One Premium shall only be responsible 
for paying the External Distribution Fee for Cboe One Premium. The 
current fee schedule provides that ``Cboe One Summary User Fees can be 
applied to Cboe One Summary and Cboe One Premium External Distribution 
Fees.'' Under the Exchange's existing application of this provision, an 
External Distributor receiving both Cboe One Summary and Cboe One 
Premium is assessed only the Cboe One Premium External Distribution 
Fee,\9\ and User Fees for both Cboe One Summary and Cboe One Premium 
may be applied to offset that fee.
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    \9\ To better illustrate this concept, consider the following 
examples. Example 1: If a firm subscribes to only Cboe One Summary, 
its User costs will be used to offset the External Distribution Fee 
for Cboe One Summary. In the event the firm's User costs total 
$2,000, the firm will pay $2,000 in User fees and $3,000 ($5,000-
$2,000) for its External Distribution Fee. Example 2: If a firm 
subscribes only to Cboe One Premium, its User costs will be used to 
offset the External Distribution Fee for Cboe One Premium. In the 
event a firm's User costs total $10,000, the firm will pay $10,000 
in User fees and $2,500 ($12,500-$10,000) for its External 
Distribution Fee. Example 3: If a firm subscribes to both Cboe One 
Summary and Cboe One Premium, only the External Distribution Fee for 
Cboe One Premium is assessed and this fee may be offset by both Cboe 
One Summary and Cboe One Premium User fees. In the event a firm's 
User costs are $2,000 for Cboe One Summary and $10,000 for Cboe One 
Premium, the firm will pay a total of $12,000 in User fees ($10,000 
+ $2,000) and it will pay $500 for its External Distribution Fee 
($12,500-($10,000 + $2,000)).
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    The Exchange is now proposing to make this treatment explicit by 
adding clarifying language to the fee schedule stating that External 
Distributors of both feeds are only responsible for paying the External 
Distribution Fee for Cboe One Premium. This amendment does not alter 
the economic substance of the Exchange's existing fee structure, nor 
does it impose any new or increased fees on market participants. 
Rather, it reduces potential ambiguity by expressly codifying the 
Exchange's existing application of the user fee offset provisions. The 
Exchange believes this clarification will promote transparency and 
reduce confusion among External Distributors regarding their fee 
obligations under the Cboe One market data product offerings.
Impact of Proposed Program
    As noted above, the proposed program would waive External 
Distribution Fees for Data Vendors of the Cboe One Summary Feed, Cboe 
One Premium Feed, EDGX Summary Depth Data Feed, and EDGX Top Data Feed 
(each, an ``Applicable Feed'') that satisfy certain eligibility 
requirements. A Data Vendor must not have received the Applicable Feed 
for which it seeks the waiver during the 18 months \10\ preceding the 
waiver application date, and must integrate, or be actively in the 
process of integrating, the Applicable Feed and making it commercially 
available to its subscribers. The Data Vendor need not have fully 
integrated the Applicable Feed or made it commercially available before 
the waiver begins. For a qualifying Data Vendor, the applicable waiver 
commences on the date it first receives the Applicable Feed, and, if 
that date occurs mid-month, that partial month counts as the first 
month of the waiver period. Specifically, the Exchange proposes to 
waive the External Distribution Fee of $5,000 per month for Cboe One 
Summary for 12 months (the ``Summary Waiver Period''), except that a 
Data Vendor is not eligible for a Summary Waiver Period if it is 
receiving Cboe One Premium because Cboe One Summary is included in the 
Cboe One Premium External Distribution Fee as noted herein. To clarify, 
because a Data Vendor receiving Cboe One Premium pays only the Cboe One 
Premium External Distribution Fee (and no separate fee is assessed for 
Cboe One Summary), there is no separate Cboe One Summary External 
Distribution Fee to waive for such a firm.\11\ The Exchange proposes to 
waive the External Distribution Fee of $12,500 per month for Cboe One 
Premium for 24 months (the ``Premium Waiver Period'').
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    \10\ The Exchange notes that this same 18-month requirement is 
the standard for its other fee waiver programs. See EDGX Equities 
Fee Schedule.
    \11\ As noted above, a firm that subscribes to both Cboe One 
Premium and Cboe One Summary is only charged the External 
Distribution Fee for Cboe One Premium. Accordingly, an eligible Data 
Vendor that builds out to both feeds simultaneously receives only 
the Premium Waiver Period.
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    If an eligible Data Vendor already receives Cboe One Summary, it 
may still receive the Premium Waiver Period if it has not received Cboe 
One Premium during the 18 months preceding the waiver application date 
and satisfies the integration and commercial availability requirement 
with respect to Cboe One Premium. During the Premium Waiver Period, the 
Data Vendor's Cboe One Summary subscription would be covered under the 
Premium Waiver, and no separate External Distribution Fee would be 
assessed for Cboe One Summary. Similarly, an eligible Data Vendor that 
builds out both Cboe One feeds simultaneously would receive only the 
Premium Waiver Period.
    Lastly, for eligible Data Vendors, the Exchange also proposes to 
waive the External Distribution Fee of $2,500 per month for EDGX 
Summary Depth for 24 months (the ``Summary Depth Waiver Period'') and 
the External Distribution Fee for EDGX Top of $2,250 for 12 months (the 
``Top Waiver Period'').
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

[[Page 47889]]

thereunder applicable to the Exchange and, in particular, the 
requirements of Section 6(b) of the Act.\12\ Specifically, the Exchange 
believes the proposed rule change is consistent with the Section 
6(b)(5) \13\ 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) \14\ requirement that the rules of an exchange not be designed 
to permit unfair discrimination between customers, issuers, brokers, or 
dealers.
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    \12\ 15 U.S.C. 78f(b).
    \13\ 15 U.S.C. 78f(b)(5).
    \14\ Id.
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    In particular, the Exchange believes the proposed rule change 
promotes just and equitable principles of trade by establishing a 
clear, objective, and transparent definition of ``Data Vendor'' that 
properly captures the characteristics distinguishing Data Vendors from 
other categories of External Distributors. The proposed definition sets 
forth specific, verifiable criteria--namely, that a Data Vendor must 
(i) be an External Distributor; (ii) be actively engaged, as part of 
its primary business objective, in the solicitation of unaffiliated 
third-party Distributors to redistribute a transformed Market Data 
Product; (iii) not maintain a brokerage relationship with Users; and 
(iv) not be an Extranet Service Provider. By establishing objective 
eligibility criteria, the proposed rule change ensures that similarly 
situated market participants are treated consistently and that the 
benefits of the Data Vendor Program are available to all External 
Distributors that meet the defined qualifications.
    The Exchange further believes that the codification of the existing 
Extranet Service Provider definition within the Fee Schedule promotes 
just and equitable principles of trade. Because the proposed Data 
Vendor definition directly references the term ``Extranet Service 
Provider,'' market participants seeking to understand their eligibility 
for the Program should not be required to consult the Cboe Global 
Markets North American Data Policies to determine how that term 
applies. By incorporating both defined terms into the Fee Schedule 
itself, the Exchange ensures that participants have access to the 
complete framework.
    The Exchange further believes that the proposed rule change removes 
impediments to and perfects the mechanism of a free and open market and 
a national market system. The Data Vendor Program is designed to 
incentivize Data Vendors to integrate the Applicable Feeds, make them 
commercially available to subscribers, and redistribute them by 
providing fee waivers for External Distribution Fees for the Cboe One 
Summary Feed, Cboe One Premium Feed, EDGX Summary Depth Data Feed, and 
EDGX Top Data Feed. By waiving the External Distribution Fee for Cboe 
One Summary for 12 months, Cboe One Premium for 24 months, EDGX Summary 
Depth for 24 months, and EDGX Top for 12 months, the Exchange 
encourages broader redistribution of its market data products. Broader 
distribution of market data enhances price transparency and supports 
informed decision-making across the national market system, which in 
turn perfects the mechanism of a free and open market by ensuring that 
market participants have access to comprehensive, competitive data 
offerings.
    By allowing the waiver to begin while an eligible Data Vendor is 
actively integrating the Applicable Feed and working to make it 
commercially available, the Program lowers barriers to entry during the 
build-out period and incentivizes a broader set of market participants 
to enter the Exchange's data distribution chain, thereby expanding the 
availability of market data throughout the national market system.
    The proposed rule change also protects investors and the public 
interest. By encouraging Data Vendors to take in, transform, and 
redistribute market data feeds, the proposed program promotes greater 
availability of enriched market data products to downstream 
Distributors and Users. The transformation requirement--which may 
include aggregation across multiple sources, normalization into a 
consistent format, enrichment with derived analytics, or repackaging 
into a proprietary delivery mechanism such as a terminal, API, or 
feed--is a key element of qualifying as a Data Vendor and ensures that 
meaningful value is added to the data before redistributing it, thereby 
increasing the utility and accessibility of market information. To the 
extent the Program achieves its purpose and results in more widespread 
redistribution of the Applicable Feeds, market participants may benefit 
from enhanced access to consolidated real-time price, depth-of-book, 
top-of-book, and last sale information through the distribution 
channels developed by Data Vendors.
    Additionally, the codification of the existing Extranet Service 
Provider definition within the Fee Schedule provides additional clarity 
on the program requirements and codifies the definition that exists 
already in the Cboe Global Markets North American Market Data Policies. 
Furthermore, the clarification that External Distributors of both Cboe 
One Summary and Cboe One Premium are only responsible for paying the 
External Distribution Fee for Cboe One Premium promotes transparency by 
expressly codifying a practice that is already reflected in the 
Exchange's existing application of the fee provision. This reduces 
potential confusion among market participants regarding their fee 
obligations.
Not Unfairly Discriminatory
    The Exchange believes that the proposed Data Vendor Program is 
consistent with and complementary to its existing programs for other 
categories of market participants, and that offering a targeted fee 
waiver program specifically for Data Vendors does not constitute unfair 
discrimination. The Exchange has a history of establishing 
differentiated programs that recognize the distinct roles of different 
market participants. For example, the Small Retail Broker Distribution 
Program, provides discounted Distribution Fees and Data Consolidation 
Fees for eligible broker-dealers distributing the applicable feeds to 
Non-Professional Data Users with whom the broker-dealer has a brokerage 
relationship.\15\ This program is designed to address the specific 
characteristics and economic needs of small retail broker-dealers. 
Similarly, the Small Retail Broker Hosted Solutions Program, provides 
fee waivers for eligible Small Retail Brokers that provide the 
applicable feeds to other Small Retail Brokers via hosted 
solutions.\16\ This program recognizes that smaller retail brokers face 
unique integration challenges and cost constraints when building out 
hosted data solutions. In addition, the New Internal Distributor Waiver 
for the EDGX Depth Data Feed waives Internal Distribution Fees for 
three months for Internal Distributors that have not received the EDGX 
Depth Data Feed during the prior 18 months.\17\ This

[[Page 47890]]

program incentivizes new Internal Distributors to integrate the depth-
of-book feed into their systems.
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    \15\ See EDGX Equities Fee Schedule.
    \16\ See EDGX Equities Fee Schedule.
    \17\ Id.
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    The proposed Data Vendor Program is consistent with this approach. 
Data Vendors occupy a distinct role in the market data distribution 
ecosystem. Unlike retail brokers, whose primary business is providing 
trade execution and account management services to Users (with market 
data distribution as an ancillary feature), Data Vendors are primarily 
engaged in the business of transforming and redistributing market data 
to other Distributors. This fundamental difference in business model 
justifies a distinct program with tailored eligibility criteria and 
waiver periods. The waiver periods under the proposed Data Vendor 
Program--12 months for Cboe One Summary and EDGX Top, and 24 months for 
Cboe One Premium and EDGX Summary Depth--are designed to reflect the 
relative complexity of integrating each feed. Depth-of-book products 
such as Cboe One Premium and EDGX Summary Depth typically require more 
extensive technical build-out, including handling of larger data 
volumes, more complex display and aggregation logic, and more rigorous 
quality assurance processes. Additionally, EDGX Summary Depth and Cboe 
One Premium are more expensive relative to the top of book of feeds. 
This means that Data Vendors require additional interest from clients 
in these products before they can even break even. Accordingly, the 
Exchange believes a 24-month waiver period for these products is 
appropriate to provide sufficient time for Data Vendors to complete 
their build-out. Top-of-book and summary products, in contrast, are 
generally less complex to integrate, and the Exchange believes a 12-
month waiver period is appropriate for these feeds.
    The Exchange does not maintain comparable fee waiver programs for 
larger broker-dealers that distribute market data to their brokerage 
customers. The Exchange believes this distinction is appropriate. The 
Small Retail Broker programs are specifically designed to address the 
cost constraints faced by smaller broker-dealers in building out market 
data distribution capabilities. Larger broker-dealers, by contrast, 
typically have established data infrastructure and greater resources to 
absorb market data distribution costs as part of their overall 
brokerage operations, and, as such, their cost per user is meaningfully 
lower. The Data Vendor Program is intended to address a different need: 
incentivizing specialized data redistribution firms to build out the 
Applicable Feeds and bring on additional downstream Distributors. By 
encouraging Data Vendors to invest in the transformation and 
redistribution of the Exchange's market data products, the Program 
expands the reach and availability of this data throughout the national 
market system, benefiting end users and promoting competition. The 
Exchange therefore believes that creating a targeted program for Data 
Vendors, in addition to its existing programs for Small Retail Brokers 
and Internal Distributors, among others, is consistent with Section 
6(b)(5) of the Act and does not constitute unfair discrimination.
    The Exchange also believes the proposed rule change is consistent 
with Section 6(b)(5) of the Act in that it is not designed to permit 
unfair discrimination between customers, issuers, brokers, or dealers. 
The Data Vendor Program is available to all External Distributors that 
satisfy the objective criteria set forth in the proposed definition of 
Data Vendor and, for waiver eligibility, the additional objective 
criteria regarding the 18-month lookback for prior receipt of the 
Applicable Feed and integration or active integration of the Applicable 
Feed for commercial availability. The distinctions drawn by the 
definition--(i) requiring that a Data Vendor's primary business 
objective be the solicitation of unaffiliated third-party Distributors, 
(ii) that it not maintain a brokerage relationship with Users, and 
(iii) that it not be an Extranet Service Provider--reflect meaningful 
differences in business models and market functions.
External Distributors
    The Exchange believes that limiting the Data Vendor Program to 
External Distributors is not unfairly discriminatory. Internal 
Distributors and External Distributors occupy fundamentally different 
roles in the market data distribution ecosystem and are not similarly 
situated participants. An Internal Distributor receives a market data 
product and distributes it solely within its own entity, whereas an 
External Distributor redistributes data outside its entity to Users or 
other Distributors--and a Data Vendor, as a specialized category of 
External Distributor, further serves the specific function of 
soliciting unaffiliated third-party Distributors to redistribute a 
transformed market data product. The Data Vendor Program is designed 
precisely to incentivize and expand this type of external 
redistribution, a purpose that has no meaningful application to 
Internal Distributors who, by definition, cannot advance the proposed 
program's goal of broadening the reach of the Exchange's market data to 
downstream Distributors and end-user investors. Furthermore, the 
Exchange already offers programs for its Internal Distributors that it 
does not offer for External Distributors.\18\
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    \18\ See, e.g., EDGX Equities Fee Schedule that describes the 
New Internal Distributor Waiver for EDGX Depth Data Feed.
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Primary Business Is To Redistribute to Distributors
    To be eligible as a Data Vendor, an External Distributor must be 
taking in data for the primary business purpose of selling access to 
the applicable feed as a service in its own right--not merely 
redistributing data in incidental support of broader business functions 
such as trade execution, account management, or brokerage services. The 
Exchange notes that as part of its business, a Data Vendor may 
redistribute a market data product to Users, but the primary purpose 
must be the redistribution of data to Distributors. The Exchange will 
assess whether an External Distributor's primary business purpose 
satisfies this criterion based on the External Distributor's publicly 
available marketing materials. This requirement is not unfairly 
discriminatory because it is directly tied to the purpose of the 
Program: encouraging entities whose core commercial activity is the 
transformation and redistribution of market data to build out the 
Applicable Feeds and bring on additional downstream Distributors, 
thereby expanding the reach and availability of the Exchange's data 
products. An entity that distributes market data only incidentally--as 
an ancillary feature of a brokerage, execution, or account management 
business--does not serve this purpose.
Transformed Market Data Product
    The Exchange believes it is not unfairly discriminatory to require 
that a Data Vendor transform market data as a condition of eligibility, 
as transformation is a definitional characteristic that goes to the 
core of what distinguishes a Data Vendor from other categories of 
External Distributors and is directly tied to the Program's purpose of 
incentivizing participants that create new, differentiated distribution 
channels for the Exchange's consolidated market data. This reasoning is 
directly analogous to the rationale for excluding Extranet Service 
Providers--entities that transmit data without modification and 
therefore cannot create the type of value-added products, whether 
delivered via terminal, API, or proprietary feed, that

[[Page 47891]]

the Program is designed to incentivize. Because the transformation 
requirement ensures that the Program's fee incentives are directed only 
at entities whose business is built around adding that value, the 
Exchange believes this criterion is reasonable and does not constitute 
unfair discrimination.
No Brokerage Relationship With Users
    The Exchange believes it is not unfairly discriminatory to require 
that Data Vendors not maintain a brokerage relationship with Users. The 
Exchange already maintains separate programs specifically for 
qualifying broker-dealers that distribute market data to their 
brokerage customers. Specifically, the Exchange offers the Small Retail 
Broker Distribution Program, which provides discounted Distribution 
Fees and Data Consolidation Fees for eligible broker-dealers 
distributing the applicable feeds to Non-Professional Data Users with 
whom the broker-dealer has a brokerage relationship. The Exchange also 
offers the Small Retail Broker Hosted Solutions Program, which provides 
fee waivers and lower data costs for Small Retail Brokers that provide 
the applicable feeds to other Small Retail Brokers via hosted 
solutions. These existing programs are specifically designed to 
encourage retail brokers to distribute market data, and the eligibility 
criteria for those programs reflect the characteristics of the retail 
brokerage business model.
    The proposed Data Vendor Program does not displace or reduce the 
benefits available to retail brokers under those existing programs. 
Rather, it creates a parallel and complementary framework for a 
distinct category of participants--Data Vendors--that do not maintain 
brokerage relationships with Users, and whose primary business purpose 
is categorically different from that of a retail broker. Just as it 
would not be appropriate to extend the Small Retail Broker Program to 
Data Vendors, it is similarly appropriate--and not unfairly 
discriminatory--not to extend the Data Vendor Program to retail brokers 
or other participants that maintain brokerage relationships with their 
Users, whose needs are separately addressed by the Exchange's existing 
programs.
Not an Extranet Service Provider
    The Exchange also believes it is not unfairly discriminatory to 
exclude Extranet Service Providers from the Data Vendor Program. An 
Extranet Service Provider, as defined, is an entity that transmits a 
market data product to data recipients without modification of the 
content, format, or other characteristics of the product. Extranet 
Service Providers do not transform, enrich, or add value to the data 
they transmit--they serve as conduits, passing data through in its 
original form. This is fundamentally distinct from the function of a 
Data Vendor, which, by definition, must transform the Market Data 
Product as part of its service offering.
    The Data Vendor Program is specifically premised on the value that 
transformation adds to the data distribution ecosystem. By enabling 
Data Vendors to create differentiated products--delivered via a 
terminal, API, proprietary feed, or other value-added mechanism--that 
appeal to a broader range of downstream Distributors, the Program 
advances the Exchange's goal of maximizing the reach and utility of its 
consolidated market data throughout the national market system. 
Extending the Program to Extranet Service Providers, which do not 
perform this transformative function, would undermine the Program's 
core purpose and would not serve the policy goal of broadening 
distribution of market data products in readily accessible, value-added 
formats.
    The Exchange has created programs to address the distinct needs and 
business models of different categories of market participants, and the 
proposed Data Vendor Program is a natural extension of this approach. 
In addition to the Small Retail Broker programs described above, the 
Exchange also offers fee waivers for eligible Internal Distributors of 
the EDGX Depth Data Feed, which are intended to incentivize new 
Internal Distributors to integrate data feeds into their systems. The 
differentiation between Data Vendors and other categories of market 
participants reflects the distinct roles these entities play and the 
distinct incentive structures appropriate to each and does not 
constitute unfair discrimination.
18-Month and Integration Requirements
    The Exchange further believes it is not unfairly discriminatory to 
limit the Program to Data Vendors that have not received the Applicable 
Feed for which they seek a waiver during the 18 months preceding the 
waiver application date, and that have integrated, or are actively in 
the process of integrating,\19\ the Applicable Feed and making it 
commercially available to subscribers. The 18-month limitation is 
designed to ensure that the fee waivers serve their intended purpose of 
reducing the upfront cost barriers for new market participants. This 
approach is directly consistent with the analogous frameworks the 
Exchange has adopted in prior programs--including the Internal 
Distributor Waiver for the EDGX Depth Data Feed, which similarly limits 
fee relief to distributors that have not received the relevant feed in 
the prior 18 months. The integration and commercial availability 
requirement is likewise reasonable because it ensures that the waiver 
is directed to Data Vendors that are undertaking the build-out 
necessary to distribute the Applicable Feed to subscribers, while not 
requiring full integration or commercial availability before the waiver 
begins. The Exchange therefore believes that these objective 
limitations are reasonable and appropriate, prevent the Program from 
operating as a permanent subsidy for established distributors, and are 
not unfairly discriminatory.
---------------------------------------------------------------------------

    \19\ The Exchange notes that no specific step is required for 
this, only that Data Vendor is working to integrate the Applicable 
Feed into its system.
---------------------------------------------------------------------------

    The Exchange also believes the proposed rule change is consistent 
with Section 6(b)(4) of the Act,\20\ which requires that Exchange rules 
provide for the equitable allocation of reasonable dues, fees, and 
other charges among its Trading Permit Holders and other persons using 
its facilities. The proposed fee waivers represent a reasonable and 
equitable allocation of charges. The fee waivers for External 
Distribution Fees are limited in duration--12 months for Cboe One 
Summary, 24 months for Cboe One Premium, 24 months for EDGX Summary 
Depth, and 12 months for EDGX Top--and are available only to Data 
Vendors that have not received the Applicable Feed for which they seek 
a waiver during the 18 months preceding the waiver application date and 
that have integrated, or are actively in the process of integrating, 
the Applicable Feed and making it commercially available to 
subscribers. This time-limited structure ensures that the waivers serve 
their intended purpose of incentivizing new market entry and build-out 
of data feeds. The 18-month lookback requirement further ensures the 
equitable allocation of fees by limiting the Program to new feeds for 
Data Vendors, and the integration and commercial availability 
requirement ensures that the waiver is tied to actual build-out and 
distribution activity. The Exchange notes that this same 18-month 
standard is consistent with the requirements applied in its other fee 
waiver programs.
---------------------------------------------------------------------------

    \20\ 15 U.S.C. 78f(b)(4).
---------------------------------------------------------------------------

    The clarification that External Distributors of both Cboe One 
Summary and Cboe One Premium shall only be

[[Page 47892]]

responsible for paying the External Distribution Fee for Cboe One 
Premium does not alter the economic substance of the Exchange's 
existing fee structure and does not impose any new or increased fees on 
market participants. Rather, it expressly codifies the Exchange's 
existing application of the user fee offset provisions--under which an 
External Distributor disseminating both products is assessed only the 
Cboe One Premium External Distribution Fee--thereby ensuring that all 
market participants have a clear and equitable understanding of their 
fee obligations. The Exchange therefore believes the proposed rule 
change provides for the equitable allocation of reasonable fees among 
persons using its facilities.
    Lastly, the Exchange believes that the limitations regarding the 
waiver structure for both Cboe One Premium and Cboe One Summary 
equitably allocate fees. With respect to the Cboe One Summary waiver, 
only Data Vendors that (i) have not received Cboe One Summary during 
the 18 months preceding the waiver application date, (ii) are 
integrating or actively in the process of integrating Cboe One Summary 
and making it commercially available to subscribers, and (iii) are not 
receiving Cboe One Premium are eligible for the Summary Waiver Period. 
The Exchange believes that this is reasonable, as a firm that 
subscribes to Cboe One Premium already may elect to receive (without 
incurring an additional External Distribution Fee) Cboe One Summary 
Feed. For this reason, there is no need to provide a separate Summary 
Waiver Period while a firm receives Cboe One Premium, because that firm 
may receive the Cboe One Summary Feed without paying an additional 
External Distribution Fee that the proposed program seeks to waive.
    Next, the Exchange notes that if a Data Vendor currently receives 
Cboe One Summary and elects to receive Cboe One Premium under the 
proposed program, so long as the Data Vendor has not received the Cboe 
One Premium Feed during the 18 months preceding the waiver application 
date and satisfies the integration and commercial availability 
requirement with respect to Cboe One Premium, the Data Vendor may 
receive the Premium Waiver Period. During that period, the Data 
Vendor's existing Cboe One Summary \21\subscription will be covered 
under the Premium Waiver, and no separate External Distribution Fee 
will be assessed for Cboe One Summary. This is because the Cboe One 
Summary External Distribution Fee is subsumed within the Cboe One 
Premium External Distribution Fee--accordingly, there is no separate 
Cboe One Summary fee to waive for a firm receiving Cboe One Premium. 
The Exchange believes this treatment is reasonable because it avoids 
providing overlapping or duplicative waiver relief while still 
incentivizing an existing Summary subscriber to build out Cboe One 
Premium.
---------------------------------------------------------------------------

    \21\ For example, if a Data Vendor currently subscribes to Cboe 
One Summary Feed and is eligible for the proposed program for the 
Cboe One Premium Feed, no separate External Distribution Fee would 
be assessed for Cboe One Summary during the Premium Waiver Period 
because Cboe One Summary is included in the Cboe One Premium 
subscription. The Data Vendor would receive the Premium Waiver 
Period and would not receive a separate Summary Waiver Period during 
that time.
---------------------------------------------------------------------------

    Lastly, if a Data Vendor has not received either Cboe One Summary 
or Cboe One Premium during the 18 months preceding the waiver 
application date and elects to build out both Cboe One feeds 
simultaneously, the Data Vendor will not receive separate Summary and 
Premium waivers. Instead, because the Cboe One Summary External 
Distribution Fee is subsumed within the Cboe One Premium External 
Distribution Fee, the Data Vendor will receive only the Premium Waiver 
Period, and no separate Summary Waiver Period will apply while it 
receives Cboe One Premium.
    With respect to EDGX Summary Depth and EDGX Top, the Exchange 
believes that the applicable waiver periods also equitably allocate 
fees. The 24-month Summary Depth Waiver Period is reasonable because 
integrating a depth-of-book product may require a more substantial 
build-out by a Data Vendor, while the 12-month Top Waiver Period is 
reasonable because EDGX Top provides top-of-book and last sale 
information and generally should require a less extensive integration 
effort. In each case, the waiver is available only if the Data Vendor 
satisfies the 18-month lookback and integration or active-integration 
requirements for the applicable feed.
    For all of the foregoing reasons, the Exchange believes the 
proposed rule change is consistent with the Act and the rules and 
regulations thereunder, including, in particular, the requirements of 
Sections 6(b)(4) \22\ and 6(b)(5) \23\ of the Act.
---------------------------------------------------------------------------

    \22\ 15 U.S.C. 78f(b)(4).
    \23\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

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 imposes any burden on intramarket 
competition that is not necessary or appropriate in furtherance of the 
purposes of the Act. The proposed Data Vendor Program is available to 
all External Distributors that satisfy the objective, clearly defined 
criteria set forth in the proposed definition of ``Data Vendor'' and 
the Program's waiver eligibility standards. Any External Distributor 
that, as part of its primary business objective, solicits unaffiliated 
third-party Distributors to redistribute a transformed Market Data 
Product, does not maintain a brokerage relationship with Users in 
connection with the applicable Market Data Product, is not an Extranet 
Service Provider, has not received the Applicable Feed for which it 
seeks a waiver during the 18 months preceding the waiver application 
date, and has integrated or is actively integrating the Applicable Feed 
and making it commercially available to subscribers may qualify for the 
Program on equal terms. Because eligibility is determined by objective, 
verifiable criteria rather than by subjective or discretionary 
determinations, no External Distributor is advantaged or disadvantaged 
relative to any other similarly situated participant.
    To the extent that certain External Distributors--such as retail 
broker-dealers or Extranet Service Providers--do not qualify for the 
Data Vendor Program, this does not impose a burden on intramarket 
competition. As described above, retail broker-dealers and Extranet 
Service Providers are not similarly situated to Data Vendors. Retail 
broker-dealers distribute market data to their own brokerage customers 
as an ancillary feature of their core business of providing trade 
execution and account management services, and their data distribution 
needs are more appropriately addressed by the Exchange's existing Small 
Retail Broker Distribution Program and Small Retail Broker Hosted 
Solutions Program. Extranet Service Providers, by contrast, transmit 
data in its original form without transformation, and therefore do not 
serve the same function in the data distribution ecosystem as Data 
Vendors, which aggregate, transform, and redistribute data to 
downstream Distributors. Designing a fee program specifically targeted 
to Data Vendors, rather than applying it uniformly across all 
categories of External Distributors, does not burden intramarket

[[Page 47893]]

competition--it reflects the materially different roles, business 
models, and barriers of these distinct categories of participants.
    Similarly, limiting the Data Vendor Program to External 
Distributors and not extending it to Internal Distributors does not 
impose a burden on intramarket competition. Internal Distributors 
receive and use market data solely within their own legal entities and 
do not redistribute data to third parties outside their organizations. 
They are therefore not participants in the same competitive market for 
external data redistribution that the Program is designed to promote, 
and their needs are separately addressed through the Exchange's 
existing Internal Distributor programs--including the New Internal 
Distributor Waiver for the EDGX Depth Data Feed. The proposed Program 
is specifically designed to incentivize external redistribution of the 
Applicable Feeds, a purpose that has no meaningful application to 
Internal Distributors and that creates no competitive disadvantage for 
them.
    The Exchange does not believe the proposed rule change imposes any 
burden on intermarket competition that is not necessary or appropriate 
in furtherance of the purposes of the Act. To the contrary, the 
Exchange believes the proposed rule change will enhance intermarket 
competition by incentivizing a broader class of market participants to 
subscribe to and redistribute the Exchange's market data products, 
thereby increasing the Exchange's ability to compete with other 
national securities exchanges and data vendors for the business of Data 
Vendors and their downstream Distributor clients.
    The market for equity market data is highly competitive. Numerous 
national securities exchanges offer products that compete directly with 
the Cboe One Summary Feed, Cboe One Premium Feed, EDGX Summary Depth 
Data Feed, and EDGX Top Data Feed. Market participants can obtain 
comprehensive market data from numerous sources, including competing 
exchanges (such as NYSE and Nasdaq), the consolidated tape (SIP), and 
alternative trading systems. Prospective Data Vendors evaluating 
whether to build out the Applicable Feeds must weigh the upfront costs 
of connectivity, software development, integration, and commercial 
launch against the commercial opportunity presented by the Exchange's 
data products. The Data Vendor Program is designed to make the 
Exchange's market data offering competitively priced relative to 
alternative options, encouraging Data Vendors to enter the Exchange's 
data distribution chain and thereby expanding the availability and 
reach of the Exchange's market data throughout the national market 
system.
    Far from burdening intermarket competition, the proposed rule 
change is a direct response to competitive market forces. The 
Exchange's decision to offer targeted fee waivers to new Data Vendors 
reflects its recognition that it must compete aggressively for the 
participation of data redistribution firms, and that reducing the 
upfront cost of entry is a legitimate and necessary competitive tool in 
the market for exchange data products. The Commission has recognized 
that exchanges operate in a competitive environment with respect to 
market data, and that exchange fee programs designed to attract new 
participants and expand market data distribution are consistent with 
the Act's goals of promoting competition and efficiency in the national 
market system.
    The proposed clarification that External Distributors of both Cboe 
One Summary and Cboe One Premium are only responsible for paying the 
External Distribution Fee for Cboe One Premium similarly does not 
impose any burden on intermarket competition. This change does not 
alter the economic substance of the Exchange's existing fee structure 
and does not impose any new fees on any market participant. It simply 
makes explicit the Exchange's existing application of the user fee 
offset provisions, reducing potential confusion and ensuring that all 
market participants have a clear and consistent understanding of their 
fee obligations. Regulatory clarity of this nature promotes, rather 
than burdens, competition by enabling market participants to make fully 
informed decisions about their participation in the Exchange's market 
data programs.
    With respect to the Cboe One Summary and Cboe One Premium feeds 
specifically, the Exchange notes that the proposed Data Vendor Program 
does not impose any burden on competition arising from differential 
pricing between Cboe One and the applicable underlying equities 
feeds.\24\ The Exchange notes that historically, its pricing for Cboe 
One products has been based on the sum of the External Distribution 
Fees for the four underlying equities feeds.\25\ As an initial matter, 
not all underlying equities feeds are offered under this Program. The 
proposed Data Vendor Program applies only to the following feeds: EDGX 
Top, EDGX Summary Depth, BZX Summary Depth, Cboe One Premium, and Cboe 
One Summary. A Data Vendor may choose to receive a waiver for Cboe One 
Summary or Cboe One Premium, or for EDGX Top, or for EDGX Summary 
Depth, or for BZX Summary Depth, or any combination thereof, subject to 
the applicable eligibility requirements. However, the proposed Program 
does not offer fee waivers for BZX Top, BYX Top, or EDGA Top data 
feeds, nor does it offer fee waivers for BYX Summary Depth or EDGA 
Summary Depth. Accordingly, the applicable underlying equities feeds do 
not ``sum'' to the applicable Cboe One feed under this proposed 
Program.\26\
---------------------------------------------------------------------------

    \24\ For Cboe One Summary, the four equities feeds are BZX Top, 
BYX Top. EDGA Top and EDGX Top. For Cboe One Premium, the four 
equities feeds are BZX Summary Depth, BYX Summary Depth, EDGA 
Summary Depth and EDGX Summary Depth.
    \25\ For example, under the Small Retail Broker Distribution 
Program, the discounted External Distribution Fee for Cboe One 
Summary is $3,500 per month, which equals the sum of the External 
Distribution Fees for the four underlying Top feeds: BZX Top 
($2,500), BYX Top ($250), EDGA Top ($0), and EDGX Top ($750). See 
Cboe BZX, BYX, EDGA, and EDGX U.S. Equities Exchange Fee Schedules. 
Because the proposed Data Vendor Program does not offer fee waivers 
for BZX Top, BYX Top, EDGA Top, BYX Summary Depth, or EDGA Summary 
Depth, the External Distribution Fee for each of those feeds would 
remain in effect for any Data Vendor receiving those feeds, while 
the External Distribution Fee for Cboe One Summary ($0 during the 
Summary Waiver Period) or Cboe One Premium ($0 during the Premium 
Waiver Period) would be waived. This results in a pricing 
differential between the sum of the underlying equities feeds and 
the Cboe One feeds under this Program.
    \26\ For example, the External Distribution Fee is $0 for Cboe 
One Summary under the proposed Program, but the sum of the four 
underlying equities feeds under the proposed Program is $2,750 ($0 
EDGX Top + $2,500 BZX Top _ + $250 BYX Top + $0 EDGA Top).
---------------------------------------------------------------------------

    Even setting aside the foregoing, the Exchange does not believe 
that pricing the Cboe One Summary or Cboe One Premium feeds differently 
from the underlying equities feeds imposes any burden on competition. 
To date, the Exchange is not aware of any distributor that purchases 
the underlying equities feeds (either the Top or Summary Depth Feeds) 
for the purpose of creating its own consolidated product comparable to 
Cboe One Summary or Cboe One Premium. This demonstrates that the 
practical market concern underlying any perceived burden--that 
distributors might be disadvantaged by differential pricing on Cboe One 
that is not extended to the underlying feeds--does not correspond to 
actual market behavior.
    Moreover, Cboe One Summary and Cboe One Premium are distinct, 
independent data products--they are not merely consolidations of data 
from the four underlying equities feeds. In addition to consolidating 
top-of-book

[[Page 47894]]

data from BZX, BYX, EDGX, and EDGA, Cboe One Summary includes 
supplementary data elements not found in the individual underlying 
feeds, including data derived from the Securities Information Processor 
(``SIP'') containing information on the national cumulative volume. 
This additional content makes Cboe One a distinct product with 
independent utility. Market participants subscribe to the underlying 
equities feeds and Cboe One for fundamentally different purposes. For 
example, a subscriber may be interested only in top-of-book data from a 
single exchange, such as EDGX, for trading, routing or compliance 
purposes. Such a subscriber has no need for a consolidated product. 
Conversely, subscribers seeking a comprehensive, cross-exchange view of 
Cboe liquidity choose Cboe One precisely because it offers consolidated 
data with additional enhancements. These distinct use cases support 
differentiated pricing treatment.
    Data Vendors may, in theory, choose to purchase each of the four 
underlying equities feeds and create their own consolidated product. 
However, this option is not economically viable in practice. Cboe One 
offers a pre-consolidated feed with additional information--including 
cumulative volume from the SIP--that is not available in the underlying 
feeds. Even before considering any fee waivers or discounts, the time, 
effort, and technical resources required for a data vendor to acquire 
the four underlying feeds, integrate them, and supplement them with 
additional data sources would exceed the cost of simply subscribing to 
Cboe One. The proposed Program therefore does not place distributors at 
a competitive disadvantage because self-consolidation is not a 
realistic market alternative.
    Section 6(b)(8) of the Exchange Act requires that exchange rules 
not impose any burden on competition that is not necessary or 
appropriate in furtherance of the purposes of the Act. Cboe One 
Summary, Cboe One Premium, and the applicable underlying equities feeds 
are separate products serving different market needs. Just as the 
Commission has permitted exchanges to offer different fees for depth-
of-book data versus top-of-book data, the Exchange should have 
discretion to price its consolidated summary product differently from 
its component feeds.
    Finally, the proposed Data Vendor Program is pro-competitive. By 
reducing the cost of consolidated and top-of-book data products for 
qualifying Data Vendors, the Exchange enables broader distribution of 
comprehensive market information to downstream distributors and, 
ultimately, to retail and institutional investors. Wider access to 
market data promotes informed investment decisions, enhances market 
efficiency, and supports the Exchange Act's goals of investor 
protection and fair and efficient markets. The Exchange does not view 
external distributors as competitors for its real-time feed offerings; 
rather, distributors serve as essential conduits that expand delivery 
of Cboe real-time market data to end users who do not have the 
technical capability or commercial need to connect directly to Cboe's 
individual market data feeds. This is particularly important for the 
retail community, as retail investors typically access market data 
through vendors rather than purchasing it directly from exchanges. By 
offering the proposed Data Vendor Program, the Exchange enables 
distributors to deliver competitively priced, comprehensive market data 
to a broader audience, thereby enhancing--not burdening--competition in 
the market data landscape.
    For the foregoing reasons, the Exchange does not believe that the 
proposed rule change imposes any burden on competition that is not 
necessary or appropriate in furtherance of the purposes of the Act.

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 foregoing rule change has become effective pursuant to Section 
19(b)(3)(A) of the Act \27\ and paragraph (f) of Rule 19b-4 \28\ 
thereunder. 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.
---------------------------------------------------------------------------

    \27\ 15 U.S.C. 78s(b)(3)(A).
    \28\ 17 CFR 240.19b-4(f).
---------------------------------------------------------------------------

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-CboeEDGX-2026-049 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-CboeEDGX-2026-049. 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 filing 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-CboeEDGX-2026-049 and should be 
submitted on or before August 19, 2026.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\29\
---------------------------------------------------------------------------

    \29\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2026-15252 Filed 7-28-26; 8:45 am]
BILLING CODE 8011-01-P