Communications with the Public

October 2018 Supplement to the Options Disclosure Document

The SEC approved the October 2018 supplement to the Options Disclosure Document (ODD). The ODD contains general disclosures on the characteristics and risks of trading standardized options. The October 2018 supplement (i) amends and restates in its entirety the April 2015 Supplement, which accommodated foreign index options and certain implied volatility index options;2 (ii) provides additional contract adjustment disclosures regarding the determination of contract adjustments by OCC rather than adjustment panels and the manner in which certain adjustments may affect an option’s value; and (iii) reflects T+2 settlement. As with other supplements to the ODD, this should be read in conjunction with the current ODD, Characteristics and Risks of Standardized Options.

FINRA Information Notice (January 17, 2019): October 2018 Supplement to the Options Disclosure Document


Prearranged Trades

Cboe restates its policy concerning prearranged trading. Trading Permit Holders are cautioned that any purchase or sale, transaction or series of transactions, coupled with an agreement, arrangement or understanding, directly or indirectly to reverse such transaction, which is not done for a legitimate economic purpose or without subjecting the transactions to market risk, violates Cboe rules and may be inconsistent with various provisions of the SEA and rules thereunder. All transactions must be effected in accordance with applicable trading rules, subject to risk of the market, and reported for dissemination.

• Cboe Regulatory Options Circular RG18-050 (December 27, 2018): Prearranged Trades


Solicited Transactions

In sum, Cboe Options Rule 6.9, Solicited Transactions: (i) sets forth priority for solicited transactions on the Exchange; and (ii) prohibits Trading Permit Holders (“TPH”) and associated persons from trading based on knowledge of an imminent undisclosed solicited transaction. This Circular is intended as a quick reference guide. Please refer to the Rule for additional information.

Cboe Regulatory Options Circular RG18-028 (August 24, 2018): Solicited Transactions



Best Execution Rule

In light of the increasingly automated market for equity securities and standardized options, and recent advances in trading technology and communications in the fixed income markets, FINRA reiterates the best execution obligations that apply when firms receive, handle, route or execute customer orders in equities, options and fixed income securities. FINRA reminds firms of their obligations, as previously articulated by the SEC and FINRA, to regularly and rigorously examine execution quality likely to be obtained from the different markets trading a security.

• FINRA Regulatory Notice 15-46 (November 2015):  Guidance on Best Execution Obligations in Equity, Options and Fixed Income Markets