SIFMA Submits Comment Letter to the CBOE Criticizing New Requirements Imposed on CBOE Trading Permit Holders

SIFMA submitted a comment letter to the Chicago Board Options Exchange ("CBOE") regarding CBOE Regulatory Circular RG14-139 and C2 Regulatory Circular RG14-040 (collectively, "the Regulatory Circulars"). The Regulatory Circulars impose new responsibilities on Trading Permit Holders ("TPHs").

In the comment letter, SIFMA asserted that the Regulatory Circulars "create new duties that go beyond interpretations of current rules" and therefore should be subject to a notice and comment period.

Furthermore, the comment letter continued, the Regulatory Circulars require that firms collect, format and successfully complete the necessary end-to-end tests with the CBOE for the over 175 data fields by January 5, 2015. SIFMA asserted that this is an unattainable implementation timeline, since firms estimate that it could take up as long as 18 months to implement a new data collection, storage and submission programs.

See: Comment Letter.