Self-Regulatory Organizations; Chicago Board Options Exchange, Incorporated; Order Granting Approval of Proposed Rule Change Relating to CBSX Trading Permit Holder Eligibility, 8771-8775 [2014-03132]
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Federal Register / Vol. 79, No. 30 / Thursday, February 13, 2014 / Notices
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.10
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–03128 Filed 2–12–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71513; File No. SR–CBOE–
2013–100]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Order Granting Approval
of Proposed Rule Change Relating to
CBSX Trading Permit Holder Eligibility
February 7, 2014.
I. Introduction
On October 23, 2013, Chicago Board
Options Exchange, Incorporated (the
‘‘Exchange’’ or ‘‘CBOE’’) filed with the
Securities and Exchange Commission
(the ‘‘Commission’’), pursuant to
Section 19(b)(1) of the Securities
Exchange Act of 1934 (the ‘‘Act’’),1 and
Rule 19b–4 thereunder,2 a proposed rule
change to add Rule 50.4A to the rules
of the CBOE Stock Exchange, LLC
(‘‘CBSX’’).3 The proposed rule change
was published for comment in the
Federal Register on November 12,
2013.4 The Commission received four
comment letters on the proposal.5 CBOE
responded to the comments on
December 20, 2013.6 On December 20,
2013, the Commission extended the
time period for Commission action to
February 10, 2014.7 This order approves
the proposed rule change.
10 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 CBSX is a stock execution facility of CBOE.
4 See Securities Exchange Act Release No. 70806
(November 5, 2013), 78 FR 67424 (‘‘Notice’’).
5 See letter from Chris Concannon, Executive Vice
President, Virtu Financial BD, LLC, to Elizabeth M.
Murphy, Secretary, Commission, dated November
11, 2013 (‘‘Virtu Letter’’); letter from Martin H.
Kaplan, Gusrae Kaplan Nusbaum PLLC, to Kevin M.
O’Neill, Deputy Secretary, Commission, dated
November 18, 2013 (‘‘Gusrae Kaplan Nusbaum
Letter’’); letter from James Ongena, General
Counsel, Chicago Stock Exchange, Inc., to Elizabeth
M. Murphy, Secretary, Commission, dated
December 3, 2013 (‘‘CHX Letter’’); and letter from
Mary Ann Burns, Chief Operating Officer, Futures
Industry Association, to Elizabeth M. Murphy,
Secretary, Commission, dated December 3, 2013
(‘‘FIA Letter’’).
6 See letter from Corinne Klott, Attorney, CBOE,
to Elizabeth M. Murphy, Secretary, Commission,
dated December 20, 2013 (‘‘CBOE Letter’’).
7 See Securities Exchange Act Release No. 71152,
78 FR 79035 (December 27, 2013).
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The Exchange proposes to adopt Rule
50.4A regarding eligibility for CBSX
Trading Permit Holders. Proposed Rule
50.4A provides that a CBSX Trading
Permit Holder (‘‘TPH’’) may become or
remain a CBSX TPH only if it is a
member of a national securities
association.8 All CBSX TPHs would
have six months from the approval of
the rule filing to become a member of
a national securities association. The
proposed rule also provides that CBSX
will terminate, upon written notice, the
TPH status of any CBSX TPH that fails
to meet this requirement.
CBOE states that it conducts
surveillance of trading on CBSX and
examines the securities-related
operations of TPHs for compliance with
CBSX Rules and the federal securities
laws, rules and regulations. CBSX TPHs
may submit orders to other trading
venues as customers through executing
broker-dealers, which are ultimately
executed on those other trading venues
(‘‘away trading activity’’). Because away
trading activity does not occur on
CBSX’s market, CBOE states that it does
not have access to all necessary order
and trade information for this trading
activity, as it does for trading activity
done directly on CBSX, from which it
can directly conduct systematic
surveillance reviews.
The Exchange notes that, although
other national securities exchanges
require their members to be members of
another national securities exchange or
a national securities association,9 the
other national securities exchanges may
not have direct access to the order and
transaction information related to the
away trading activity of their members,
as is the case with CBOE, and thus may
not be in a position to review the away
trading activity for potential violations
of federal securities laws, rules and
regulations.10 The Exchange states that
requiring a CBSX TPH to be a member
of a national securities association (i.e.
FINRA), but not providing it the option
of becoming a member of another
national securities exchange, is
appropriate to ensure that the CBSX
TPH’s away trading activity is subject to
appropriate regulatory review.
According to the Exchange, FINRA rules
currently require each FINRA member
to submit order data for trading activity
on all venues (including away trading
activity) to FINRA on a regular basis.11
The Exchange explains that this order
data audit trail provides FINRA the
necessary information related to each
member’s away trading activity to
review for and detect possible violations
of the federal securities laws, rules and
regulations. This, in turn, would allow
FINRA to detect possible violations of
federal securities laws, rules, and
regulations, and take appropriate
regulatory and disciplinary action
against a CBSX TPH as one of its
regulators, or otherwise refer such
matter to CBOE for review and
consideration of disciplinary action.
Proposed Rule 50.4A requires CBSX
TPHs to become a member of FINRA
within six months of the date of
approval of this rule change.12 CBOE
will announce the date by which CBSX
TPHs must comply with this new
requirement (the ‘‘Compliance Date’’) in
a Regulatory Circular.13 The Exchange
notes that if it determines that there are
extenuating circumstances which result
in a CBSX TPH not being able to comply
by the Compliance Date, the Exchange
may permit the CBSX TPH to retain its
TPH status beyond the Compliance Date
for such period of time as the Exchange
deems reasonably necessary to enable
the CBSX TPH to become a member of
FINRA.14
8 Currently, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) is the only registered
national securities association. CBOE states that this
proposal furthers compliance with Undertaking O
of the June 11, 2013 Order Instituting
Administrative and Cease-and-Desist Proceedings
involving CBOE and C2 Options Exchange, Inc.,
which requires CBOE to enhance its regulation of
CBSX-only TPHs. CBOE notes that this proposed
rule change is only one component of its efforts to
enhance its regulation of all CBSX TPHs, including
CBSX-only TPHs. CBOE notes that although there
will technically no longer be any CBSX-only TPHs
if the proposed rule change is approved, the
Exchange still believes that the proposal will
enhance the general regulatory oversight of CBSX
TPHs, including those former CBSX-only TPHs.
9 See, e.g., BATS Exchange, Inc. Rule 2.3, BATS
Y-Exchange, Inc. Rule 2.3, EDGA Exchange, Inc.
Rule 2.3(a), EDGX Exchange, Inc. Rule 2.3(a),
NASDAQ Stock Market LLC Rule 1002(e), and New
York Stock Exchange LLC Rule 2.
10 The Exchange notes that it may obtain an audit
trail of this ‘‘away activity’’ from which it will be
able to conduct direct systematic surveillance
reviews once the National Market System
consolidated audit trail is finalized and
implemented.
11 See, e.g., FINRA Rules 7440 and 7450.
12 As of December 20, 2013, 38 CBSX TPHs would
be affected by this eligibility requirement (i.e., are
not already members of FINRA).
13 The Exchange will also issue periodic written
reminders to all CBSX TPHs affected by this
requirement that the CBSX TPH must become a
FINRA member by the Compliance Date.
14 The Exchange notes that the ability to extend
certain time limits where extenuating
circumstances exist is consistent with and similar
to other Exchange rules. See e.g., CBOE Rule 3.19
and CBOE Rule 3.30.
II. Description of the Proposal
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III. Discussion of Comment Letters,
CBOE’s Response, and Commission
Findings
After careful review and for the
reasons discussed below, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act, including
Section 6 of the Act,15 and the rules and
regulations thereunder applicable to a
national securities exchange.16 In
particular, the Commission finds that
the proposed rule change is consistent
with Section 6(b)(5) of the Act,17 which
requires, among other things, that the
rules of a national securities exchange
be designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest, and
not be designed to permit unfair
discrimination between customers,
issuers, brokers, or dealers. In addition,
the Commission finds that the proposal
is consistent with Section 6(b)(2) of the
Act,18 which requires that the rules of
a national securities exchange provide
that any registered broker or dealer may
become a member of such exchange.
The Commission also finds that the
proposed rule change is consistent with
Section 6(b)(8) of the Act,19 which
requires that the rules of a national
securities exchange not impose any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Act.
The Commission received four
comment letters on the proposed rule
change.20 All four commenters object to
the proposed rule change, argue that it
is inconsistent with the Act, and
recommend that CBOE either enter into
a regulatory services agreement or a
Rule 17d–2 21 plan with FINRA. In
response, CBOE states that none of the
comments provide a basis for
disapproval of the proposal and
reiterates its position that the proposal
meets the standards for approval under
the Act.22 The comments, CBOE’s
response, and the Commission’s
findings are discussed in detail below.
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15 15
U.S.C. 78f.
16 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
17 15 U.S.C. 78f(b)(5).
18 15 U.S.C. 78f(b)(2).
19 15 U.S.C. 78f(b)(8).
20 See supra, note 5.
21 17 CFR 240.17d–2.
22 See CBOE Letter.
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enumerated in Section 6(c) of the Act.32
CBOE also notes that other national
securities exchanges have membership
Two commenters 23 argue that the
with another national securities
proposed rule change violates Section
exchange or national securities
6(b)(2) of the Act 24 because the proposal
association as a condition for
would impose requirements for
membership.33
exchange membership beyond those
The Commission believes that the
contained in the Act. Section 6(b)(2) of
proposed rule change is consistent with
the Act provides that ‘‘[a]n exchange
Section 6(b)(2) and Section 6(c) of the
shall not be registered as a national
Act. While Section 6(c) specifies certain
securities exchange unless the
bases upon which a national securities
Commission determines that . . .
exchange can deny membership to,
subject to the provisions of subsection
among other entities, a broker or a
(c) of this section, the rules of the
dealer, Section 6(c) is not intended to
exchange provide that any registered
provide an exclusive list of reasons a
broker or dealer . . . may become a
national securities exchange can deny
member of such exchange. . .’’ 25 The
membership to a party. National
two commenters state that the proposal
securities exchanges may have
violates Section 6(b)(2) because it
requirements for exchange membership
effectively denies or excludes certain
beyond those contained in the Act so
registered broker-dealers from
long as they are consistent with the
26
membership (TPH status) with CBSX.
Act.34 For example, the Commission has
One of the commenters asserts that
approved the rules of several national
CBOE incorrectly interprets Section
securities exchanges that require
6(b)(2) as permitting it to exclude
membership with another SRO as a
certain registered broker-dealers based
condition of membership.35 The
on their affiliation with certain other
Commission believes that CBOE’s
self-regulatory organizations
proposal requiring CBSX TPHs to be
(‘‘SROs’’).27 The other commenter
members of FINRA, another SRO, is
28
points to Section 6(c) of the Act,
consistent with Section 6(b)(2) and
which provides specific reasons for
Section 6(c) of the Act.
which a registered broker-dealer may be
prohibited from becoming a member of
B. Discrimination Among CBOE
an exchange, as further evidence that
Members
the proposal is in violation of Section
Two commenters assert that the
6(b)(2) of the Act.29 The commenter
proposal violates Section 6(b)(5) 36 by
notes that none of the bases in Section
discriminating against CBSX TPHs.37
6(c) permit an exchange to deny
Section 6(b)(5) provides, among other
membership to a broker-dealer solely on
things, that the rules of an exchange
the basis of not being a member of a
must not be designed to permit unfair
national securities association.30
discrimination between customers,
In response, CBOE states that it is
issuers, brokers, or dealers. One
incorrect to infer from these statutory
commenter states that the proposal
provisions that any registered brokerresults in certain CBOE members that
dealer meeting the general requirements are not FINRA members being denied
of Section 6(b)(2) and that does not fall
access to CBSX (CBOE’s exchange
within the categories enumerated in
facility for equities), while other CBOE
Section 6(c) is always entitled to
members that are not FINRA members
membership.31 CBOE notes that the
will continue to have access to the
rules of national securities exchanges
CBOE options facility, thus effectively
virtually always provide bases for denial discriminating against members that
of membership in addition to those
trade equities.38 The other commenter
A. Statutory Requirements for Exchange
Membership
23 See
Virtu Letter and FIA Letter.
24 15 U.S.C. 78f(b)(2).
25 Section 6(c) of the Act provides bases for denial
of membership in a national securities exchange,
including failure to register as a broker-dealer,
statutory disqualification, or failure to meet the
standards of financial responsibility or operational
capacity, or a showing that the party has or that
there is a reasonable likelihood that they may
engage in acts or practices inconsistent with just
and equitable principles of trade.
26 See Virtu Letter, at 2; FIA Letter, at 3–4.
27 See Virtu Letter, at 2.
28 15 U.S.C. 78f(c).
29 See FIA Letter, at 3–4.
30 Id.
31 See CBOE Letter, at 3.
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shares the same concern and states that
this disparate treatment is
impermissible under the Act.39
32 Id.
33 See CBOE Letter, at 3–4. CBOE also noted that
former NYSE Rule 2(b) required membership in
FINRA as a condition precedent to becoming or
remaining a member organization. Id., at 4.
34 See e.g. CHX Article 3; Rules of BATS
Exchange, Chapter II; Nasdaq Stock Market Rule
1000 series.
35 See supra, note 9.
36 15 U.S.C. 78f(b)(5).
37 See Virtu Letter; CHX Letter.
38 See Virtu Letter, at 2.
39 See CHX Letter, at 3.
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CBOE responds to these concerns by
stating that Section 6(b)(5) requires only
that exchange rules be designed not to
permit unfair discrimination and that
CBOE may impose ‘‘requirements on a
subgroup of members who elect to avail
themselves of specified exchange
services or who conduct specified types
of business,’’ while not imposing such
requirements ‘‘on other members who
choose not to use such services or
conduct such types of business, or
otherwise where such additional
requirements would serve a valid
regulatory purpose.’’ 40 The Exchange
argues that the proposed rule is justified
by the need for greater regulatory
oversight of the away trading activity of
CBSX TPHs. Because away trading
activity does not occur on the CBSX
market, CBOE states that it does not
have access to all the necessary order
and trade information for this trading
activity with which to directly conduct
systematic surveillance reviews relating
to this trading activity.41 CBOE believes
that because FINRA’s rules require each
FINRA member to submit order data for
its trading activity on all trading venues
on a regular basis, FINRA has greater
access to off-exchange trading activity
conducted by its members than do
national securities exchanges.42
Therefore, CBOE believes that its
proposal to require FINRA membership
of CBSX TPHs is reasonably designed to
enhance regulatory oversight of CBSX
TPHs so it does not unfairly
discriminate among CBOE TPHs, but
rather imposes a reasonable additional
obligation on those CBOE TPHs who
choose to be CBSX TPHs as well.43
The Commission believes that the
proposal is consistent with Section
6(b)(5) of the Act. The Commission
believes that the proposal does not
unfairly discriminate against CBSX
TPHs. As CBOE stated, Section 6(b)(5)
does not prevent an exchange from
imposing additional requirements on a
subgroup of members who elect to avail
themselves of specified exchange
services or who conduct certain types of
business. Here, CBOE’s proposal to
require CBSX TPHs to be members of
40 See
CBOE Letter, at 6.
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41 Id.
42 Id., at 6–7. CBOE also explains that, as a
member of the Intermarket Surveillance Group,
CBOE receives an equity audit trail of all equity
market orders and trade information for away
trading activity, but that the audit trail does not
provide the necessary granular level of detail to
denote when a CBSX TPH is executing a trade as
a customer through another broker-dealer on an
away market. CBOE states that without such
granular information, the Exchange is limited in the
reviews it can conduct of this activity. Id., at 6, note
22.
43 Id., at 7.
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FINRA while not requiring CBOE TPHs
to be members of FINRA is not unfairly
discriminatory because it will apply
equally to all CBSX TPHs and enhance
the regulatory oversight of CBSX TPHs’
trading activity.
C. Cost
Three commenters argue that the
proposed rule change imposes a
substantial cost on CBSX TPHs by
requiring dual membership with
FINRA.44 One commenter believes that
the proposal will make it prohibitively
expensive for some CBSX TPHs to
continue to hold CBSX trading permits
or become members of other exchanges,
thereby imposing a burden on
competition not necessary or
appropriate in furtherance of the
purposes of the Act in violation of
Section 6(b)(8).45 The commenter argues
that CBSX TPHs that are proprietary
trading firms that do not carry public
customer accounts would be required to
bear the same costs of FINRA
membership as CBSX TPHs that carry
public customer accounts.46 The
commenter further states that the
‘‘burdens on competition are not
appropriate because [s]ection 17(d) of
the Act provides the mechanism
through which an SRO could share
certain regulatory responsibilities with
other SROs . . .’’ 47 Another commenter
criticizes the proposal stating that dual
FINRA membership places a large
burden on members including, but not
limited to, an additional layer of
regulatory costs and being subject to
compliance with FINRA rules, which
have no relevance to proprietary traders
who do not have public customers.48
A third commenter points out that
‘‘undertaking FINRA membership is a
significant, time-consuming and
expensive exercise.’’ 49 The commenter
explains that FINRA membership would
require firms (1) to review and analyze
the applicability of a vast array of rules
and interpretations from FINRA, the
majority of which are designed for firms
that transact customer business; (2) to
amend filings with other exchanges,
incurring additional unnecessary filing
costs; (3) to maintain blanket fidelity
bond coverage, which the commenter
states is typically designed to insure a
firm against intentional fraudulent and
dishonest acts involving customer funds
or customer accounts, while the firms
affected by the proposed rule change do
44 See
Gusrae Nusbaum Kaplan Letter, CHX
Letter, and FIA Letter.
45 See CHX Letter, at 2–3.
46 Id., at 3.
47 Id.
48 See Gusrae Nusbaum Kaplan Letter, at 2.
49 See FIA Letter, at 4.
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not transact customer business; (4) to
incur the costs of reporting to FINRA’s
order audit trail system; and (5) to
require their associated persons to pass
additional exams, since certain exams
(such as the Series 56) are not
recognized by FINRA.50 The commenter
states that if this proposed rule goes into
effect, CBSX would be the only
exchange requiring FINRA membership
for member firms that do not transact
customer business and therefore would
position CBSX as an outlier and subject
to possible regulatory arbitrage, which
could increase market fragmentation.51
In response to these concerns, CBOE
states that any CBSX TPH that finds it
burdensome to become a FINRA
member can resign its CBSX
membership and become a member of a
national securities exchange that does
not require membership with FINRA.52
CBOE states, ‘‘[t]here are any number of
national securities exchanges that
would provide the alternative, so the
Proposal imposes no burden on
competition that a CBSX TPH cannot
easily eliminate if it chooses.’’ 53 CBOE
also states that if a CBSX TPH cannot
comply with the proposal by the
Compliance Date due to extenuating
circumstances, CBOE may permit the
CBSX TPH to retain its status as a TPH
for a time CBOE deems reasonably
necessary for the CBSX TPH to become
a member of FINRA.54 Regarding dual
registration, CBOE notes that other
national securities exchanges require
membership in another SRO.55 Further,
according to the Exchange, CBSX TPHs
that do not conduct a public customer
business would be subject only to those
FINRA rules that were applicable to
their business.56 CBOE also notes that if
associated persons of CBSX TPHs are
currently licensed in a registration
category that FINRA does not recognize,
FINRA’s rules permit FINRA to waive
its licensing requirements and accept
other standards for qualifying for
registration.57
The Commission believes that the
proposal is consistent with Section
6(b)(8) of the Act and does not impose
any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Act. As CBOE
stated, any firm that determines not to
become a FINRA member can join
another national securities exchange
50 Id.,
at 4–5.
at 6.
52 See CBOE Letter, at 9.
53 Id.
54 Id., at 10.
55 Id., at 9.
56 Id., at 11.
57 See CBOE Letter, at 11.
51 Id.,
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that does not require FINRA
membership. The Commission, as noted
above, has approved the membership
rules of several exchanges that require
membership with another SRO as a
condition of membership.58
D. Section 15(b)(8) of the Act and Rule
15b9–1 Thereunder
One commenter 59 argues that the
proposal conflicts with Section 15(b)(8)
of the Act 60 and Rule 15b9–1
thereunder.61 Section 15(b)(8) of the Act
prohibits a registered broker or dealer
from effecting a transaction in a security
unless the broker or dealer is a member
of a national securities association or
effects transactions in securities solely
on a national securities exchange of
which it is a member. Rule 15b9–1(a)
exempts a broker or dealer from
becoming a member of a national
securities association if it: (1) Is a
member of a national securities
exchange; (2) carries no customer
accounts; and (3) has annual gross
income of no more than $1,000 that is
derived from securities transactions
otherwise than on an exchange of which
it is a member.62 The commenter
believes that the proposed rule change
conflicts with these provisions because
it would require all CBSX TPHs—even
those that would qualify for the Rule
15b9–1 exemption—to become members
of a national securities association.63
The commenter states this directly
contradicts Rule 15b9–1, which
recognizes that certain broker-dealers
should not be required to become
members of a national securities
association.64
In its response, CBOE states that
neither Section 15(b)(8) nor Rule 15b9–
1 preclude CBOE from adopting a more
restrictive rule concerning when a
member must become a member of a
national securities association.65 In fact,
CBOE claims that exchanges often
impose requirements on their members
that are stricter than those specifically
enumerated in the Exchange Act and
Commission rules.66 CBOE believes that
Rule 15b9–1 ‘‘has no application if the
requirement to become a member of a
national securities association is
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58 See
supra, note 9.
59 See CHX Letter, at 2.
60 15 U.S.C. 78o(b)(8).
61 17 CFR 240.15b9–1.
62 Rule 15b9–1(b) states that the gross income
limitation in (a) does not apply to income derived
from transactions (1) for the dealer’s own account
with or through another registered broker or dealer
or (2) through the Intermarket Trading System.
63 See CHX Letter, at 2.
64 Id.
65 See CBOE Letter, at 5.
66 Id.
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required not by Section 15(b)(8) of the
[Act], but by some other authority, such
as an exchange rule.’’ 67
The Commission does not believe that
the proposed rule change conflicts with
Section 15(b)(8) or Rule 15b9–1. As
CBOE stated, national securities
exchanges may impose requirements on
their members that are more stringent
than those imposed by the Act or by
Commission rules. Therefore, the
requirement imposed by proposed Rule
50.4A that CBSX TPHs become
members of FINRA, although more
restrictive than Section 15(b)(8), is
consistent with the Act and not in
violation of Section 15(b)(8) or Rule
15b9–1.
E. Satisfaction of Regulatory Obligations
One commenter 68 believes that the
proposed rule change is an admission of
CBOE’s failure to satisfy its exchange
obligations, in violation of Section
6(b)(1) of the Act, which requires an
exchange to, among other things,
enforce compliance by its members with
provisions of the Act and the rules
thereunder.69 The commenter argues it
is not appropriate for an exchange to
alter its membership requirements in
order to satisfy its regulatory burden
and that if CBOE fails to satisfy its
regulatory responsibilities, then CBOE’s
status as an exchange and its ability to
operate the CBSX must be scrutinized.70
This commenter and another
commenter observe that the issue of
CBOE not having access to all necessary
order and trade information for away
trading activity is not unique to CBOE,
yet other exchanges have been able to
fulfill their exchange obligations
regardless.71 Specifically, the other
commenter argues that other exchanges
have not shifted the costs associated
with surveillance and monitoring to
certain of its member firms by imposing
a burdensome new membership
requirement at FINRA in order to
discharge their regulatory obligations.72
A third commenter states that the
proposal is an inefficient attempt by the
CBOE to remedy a fundamental break
down in its regulatory structure, that
67 Id.
68 See
Virtu Letter, at 1, 3.
U.S.C. 78f(b)(1). Section 6(b)(1) of the Act
states that ‘‘[a]n exchange shall not be registered as
a national securities exchange unless the
Commission determines that . . . [s]uch exchange
is so organized and has the capacity to be able to
carry out the purposes of this title and to comply,
and . . . to enforce compliance by its members and
persons associated with its members, with the
provisions of this title, the rules and regulations
thereunder, and the rules of the exchange.’’
70 See Virtu Letter, at 3.
71 Id. and FIA Letter, at 6.
72 See FIA Letter, at 6.
69 15
PO 00000
Frm 00097
Fmt 4703
Sfmt 4703
instead of building up its own
surveillance and enforcement
departments and abilities, the CBOE is
shifting the burden entirely onto its
members and FINRA.73 Finally, a fourth
commenter states that it is concerned
with the precedent that will be set if the
proposal is approved, specifically that
an SRO will be permitted to adopt rules
that will unilaterally shift some of its
responsibilities to another SRO.74
All four commenters suggest that a
better resolution would be for CBOE to
enter into a Rule 17d–2 plan or a
regulatory services agreement with
FINRA in lieu of the proposed rule
change.75 One commenter recommends
that CBOE either adopt a rule requiring
its members to send their trading
activity data to FINRA, or that CBOE
enter into a regulatory services
agreement with FINRA allowing FINRA
to collect this data and surveil it.76 The
other commenters were in favor of
CBOE entering into Rule 17d–2 plan.77
In response, CBOE reiterates that the
proposal is designed to enhance the
regulation of CBSX.78 CBOE explains
that it does not have access to all of the
necessary order and trade information
for away trading activity and that the
proposal addresses this limitation on its
ability to oversee away trading
activity.79 CBOE further explains that
entering into a 17d–2 agreement with
FINRA is not possible to address the
away trading activity of CBSX TPHs
because a 17d–2 agreement is available
only with respect to broker-dealers that
are members of each SRO that is a party
to the agreement, and by definition, the
proposal addresses the situation in
which CBSX TPHs are not FINRA
members.80 CBOE acknowledges that
there may be other ways to accomplish
its regulatory goal, but that it has
determined that its proposal is a
reasonable method of achieving its
regulatory objectives.81 CBOE also
reiterates its position that its proposal is
consistent with the Exchange Act and
notes that this is further evidenced by
the fact that the Commission has
previously approved exchange rules
requiring members to be members of at
least one other SRO.82
73 See
Gusrae Kaplan Nusbaum Letter, at 2.
CHX Letter, at 1.
75 See Virtu Letter, at 1–2; Gusrae Kaplan
Nusbaum Letter, at 3; CHX Letter, at 3; and FIA
Letter, at 6.
76 See Gusrae Kaplan Nusbaum Letter, at 3.
77 See Virtu Letter, at 1–2; CHX Letter, at 3; and
FIA Letter, at 6.
78 See CBOE Letter, at 7.
79 Id.
80 Id., at 7–8.
81 Id., at 8.
82 Id. CBOE also stated that because other
exchanges also require their members to be
74 See
E:\FR\FM\13FEN1.SGM
13FEN1
Federal Register / Vol. 79, No. 30 / Thursday, February 13, 2014 / Notices
The Commission does not believe that
CBOE’s proposal, in and of itself,
provides evidence that CBOE has failed
to meet its exchange obligations. The
Commission also notes that CBOE’s
proposal in no way (1) reduces CBOE’s
obligations under the Act to meet its
regulatory responsibilities as an SRO, or
(2) shifts any of CBOE’s responsibilities
to FINRA. The Commission agrees with
CBOE that a Rule 17d–2 plan is
available as an option only with respect
to broker-dealers that are members of
each SRO that is a party to the
agreement. CBOE has proposed to
require CBSX members to be members
of FINRA in order to enhance regulation
of their away trading activity. Whether
or not there may be other less costly or
burdensome ways to enhance regulation
of away trading activity by CBSX
members, the issue before the
Commission is whether the current
proposal is consistent with the
Exchange Act and the rules and
regulations thereunder applicable to
SROs. If so, the Commission must
approve the proposed rule change. The
Commission believes that the proposal
is consistent with the Act. As stated
above, exchanges may impose
membership requirements that are more
stringent than those contained in the
Act. The Commission has previously
approved rules of other exchanges
requiring membership in another SRO.
IV. Conclusion
For all the reasons discussed above,
the Commission finds that the proposed
rule change is consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
national securities exchanges. It is
therefore ordered, pursuant to Section
19(b)(2) of the Act,83 that the proposed
rule change (SR–CBOE–2013–100) be,
and it is hereby approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.84
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–03132 Filed 2–12–14; 8:45 am]
emcdonald on DSK67QTVN1PROD with NOTICES
BILLING CODE 8011–01–P
members of at least one other SRO, it is evident that
its proposal does not reflect that it is in violation
of Section 6(b)(1). Id., at note 25.
83 15 U.S.C. 78s(b)(2).
84 17 CFR 200.30–3(a)(12).
VerDate Mar<15>2010
18:44 Feb 12, 2014
Jkt 232001
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71509; File No. SR–CBOE–
2014–010]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change Relating to a Fee for
Qualification Examination Waiver
Requests
February 7, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on February
3, 2014, Chicago Board Options
Exchange, Incorporated (the ‘‘Exchange’’
or ‘‘CBOE’’) 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.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
Chicago Board Options Exchange,
Incorporated (the ‘‘Exchange’’ or
‘‘CBOE’’) proposes to establish a fee for
qualification examination waiver
requests. The text of the proposed rule
change is available on the Exchange’s
Web site (https://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.
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00098
Fmt 4703
Sfmt 4703
8775
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
CBOE Rule 3.6A, Interpretation and
Policy .05, authorizes the Exchange, in
exceptional cases and where good cause
is shown, to waive qualification
examinations and accept other
standards as evidence of an applicant’s
qualification for registration. This
authority is to be exercised in
exceptional cases and where good cause
is shown by the applicant. The rule
further states that advanced age or
physical infirmity, will not individually
of themselves constitute sufficient
grounds to waive a qualification
examination. Experience in fields
ancillary to the securities business may
constitute sufficient grounds to waive a
qualification examination.
The Exchange has entered into a
regulatory services agreement (‘‘RSA’’)
with the Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) pursuant to
which FINRA will process qualification
examination waiver requests on behalf
of the Exchange (‘‘Waiver Requests’’).3
Under the RSA, CBOE Trading Permit
Holders (‘‘TPHs’’) and persons
associated with CBOE TPHs seeking a
waiver of a qualification examination
will submit a Waiver Request to
FINRA.4 FINRA will process all Waiver
Requests submitted by CBOE TPHs and
their associated persons, whether the
Waiver Request is for a FINRA
examination or a non-FINRA
examination (e.g., the Series 56
examination).
FINRA will review each Waiver
Request based on guidelines approved
by the Exchange and provide the
Exchange with a recommendation
regarding the disposition of the Waiver
Request. The Exchange will make the
final decision regarding whether or not
to grant or deny a Waiver Request.5
FINRA will maintain files and records
made, collected or otherwise created by
FINRA in the course of performing
services under the RSA. Such files and
records shall include, but not be limited
to, FINRA Waiver Request disposition
recommendations and the basis for its
3 CBOE Rule 15.9(b) authorizes the Exchange to
enter into agreements with another self-regulatory
organization to provide regulatory services to the
Exchange to assist the Exchange in discharging its
obligations under Section 6 and Section 19(g) of the
Securities Exchange Act of 1934.
4 Currently, Waiver Requests must be submitted
to FINRA through the FINRA Firm Gateway.
5 Notwithstanding the RSA, the Exchange shall
retain ultimate legal responsibility for, and control
of, its self-regulatory responsibilities.
E:\FR\FM\13FEN1.SGM
13FEN1
Agencies
[Federal Register Volume 79, Number 30 (Thursday, February 13, 2014)]
[Notices]
[Pages 8771-8775]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-03132]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-71513; File No. SR-CBOE-2013-100]
Self-Regulatory Organizations; Chicago Board Options Exchange,
Incorporated; Order Granting Approval of Proposed Rule Change Relating
to CBSX Trading Permit Holder Eligibility
February 7, 2014.
I. Introduction
On October 23, 2013, Chicago Board Options Exchange, Incorporated
(the ``Exchange'' or ``CBOE'') filed with the Securities and Exchange
Commission (the ``Commission''), pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the ``Act''),\1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to add Rule 50.4A to the rules of
the CBOE Stock Exchange, LLC (``CBSX'').\3\ The proposed rule change
was published for comment in the Federal Register on November 12,
2013.\4\ The Commission received four comment letters on the
proposal.\5\ CBOE responded to the comments on December 20, 2013.\6\ On
December 20, 2013, the Commission extended the time period for
Commission action to February 10, 2014.\7\ This order approves the
proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ CBSX is a stock execution facility of CBOE.
\4\ See Securities Exchange Act Release No. 70806 (November 5,
2013), 78 FR 67424 (``Notice'').
\5\ See letter from Chris Concannon, Executive Vice President,
Virtu Financial BD, LLC, to Elizabeth M. Murphy, Secretary,
Commission, dated November 11, 2013 (``Virtu Letter''); letter from
Martin H. Kaplan, Gusrae Kaplan Nusbaum PLLC, to Kevin M. O'Neill,
Deputy Secretary, Commission, dated November 18, 2013 (``Gusrae
Kaplan Nusbaum Letter''); letter from James Ongena, General Counsel,
Chicago Stock Exchange, Inc., to Elizabeth M. Murphy, Secretary,
Commission, dated December 3, 2013 (``CHX Letter''); and letter from
Mary Ann Burns, Chief Operating Officer, Futures Industry
Association, to Elizabeth M. Murphy, Secretary, Commission, dated
December 3, 2013 (``FIA Letter'').
\6\ See letter from Corinne Klott, Attorney, CBOE, to Elizabeth
M. Murphy, Secretary, Commission, dated December 20, 2013 (``CBOE
Letter'').
\7\ See Securities Exchange Act Release No. 71152, 78 FR 79035
(December 27, 2013).
---------------------------------------------------------------------------
II. Description of the Proposal
The Exchange proposes to adopt Rule 50.4A regarding eligibility for
CBSX Trading Permit Holders. Proposed Rule 50.4A provides that a CBSX
Trading Permit Holder (``TPH'') may become or remain a CBSX TPH only if
it is a member of a national securities association.\8\ All CBSX TPHs
would have six months from the approval of the rule filing to become a
member of a national securities association. The proposed rule also
provides that CBSX will terminate, upon written notice, the TPH status
of any CBSX TPH that fails to meet this requirement.
---------------------------------------------------------------------------
\8\ Currently, Financial Industry Regulatory Authority, Inc.
(``FINRA'') is the only registered national securities association.
CBOE states that this proposal furthers compliance with Undertaking
O of the June 11, 2013 Order Instituting Administrative and Cease-
and-Desist Proceedings involving CBOE and C2 Options Exchange, Inc.,
which requires CBOE to enhance its regulation of CBSX-only TPHs.
CBOE notes that this proposed rule change is only one component of
its efforts to enhance its regulation of all CBSX TPHs, including
CBSX-only TPHs. CBOE notes that although there will technically no
longer be any CBSX-only TPHs if the proposed rule change is
approved, the Exchange still believes that the proposal will enhance
the general regulatory oversight of CBSX TPHs, including those
former CBSX-only TPHs.
---------------------------------------------------------------------------
CBOE states that it conducts surveillance of trading on CBSX and
examines the securities-related operations of TPHs for compliance with
CBSX Rules and the federal securities laws, rules and regulations. CBSX
TPHs may submit orders to other trading venues as customers through
executing broker-dealers, which are ultimately executed on those other
trading venues (``away trading activity''). Because away trading
activity does not occur on CBSX's market, CBOE states that it does not
have access to all necessary order and trade information for this
trading activity, as it does for trading activity done directly on
CBSX, from which it can directly conduct systematic surveillance
reviews.
The Exchange notes that, although other national securities
exchanges require their members to be members of another national
securities exchange or a national securities association,\9\ the other
national securities exchanges may not have direct access to the order
and transaction information related to the away trading activity of
their members, as is the case with CBOE, and thus may not be in a
position to review the away trading activity for potential violations
of federal securities laws, rules and regulations.\10\ The Exchange
states that requiring a CBSX TPH to be a member of a national
securities association (i.e. FINRA), but not providing it the option of
becoming a member of another national securities exchange, is
appropriate to ensure that the CBSX TPH's away trading activity is
subject to appropriate regulatory review. According to the Exchange,
FINRA rules currently require each FINRA member to submit order data
for trading activity on all venues (including away trading activity) to
FINRA on a regular basis.\11\ The Exchange explains that this order
data audit trail provides FINRA the necessary information related to
each member's away trading activity to review for and detect possible
violations of the federal securities laws, rules and regulations. This,
in turn, would allow FINRA to detect possible violations of federal
securities laws, rules, and regulations, and take appropriate
regulatory and disciplinary action against a CBSX TPH as one of its
regulators, or otherwise refer such matter to CBOE for review and
consideration of disciplinary action.
---------------------------------------------------------------------------
\9\ See, e.g., BATS Exchange, Inc. Rule 2.3, BATS Y-Exchange,
Inc. Rule 2.3, EDGA Exchange, Inc. Rule 2.3(a), EDGX Exchange, Inc.
Rule 2.3(a), NASDAQ Stock Market LLC Rule 1002(e), and New York
Stock Exchange LLC Rule 2.
\10\ The Exchange notes that it may obtain an audit trail of
this ``away activity'' from which it will be able to conduct direct
systematic surveillance reviews once the National Market System
consolidated audit trail is finalized and implemented.
\11\ See, e.g., FINRA Rules 7440 and 7450.
---------------------------------------------------------------------------
Proposed Rule 50.4A requires CBSX TPHs to become a member of FINRA
within six months of the date of approval of this rule change.\12\ CBOE
will announce the date by which CBSX TPHs must comply with this new
requirement (the ``Compliance Date'') in a Regulatory Circular.\13\ The
Exchange notes that if it determines that there are extenuating
circumstances which result in a CBSX TPH not being able to comply by
the Compliance Date, the Exchange may permit the CBSX TPH to retain its
TPH status beyond the Compliance Date for such period of time as the
Exchange deems reasonably necessary to enable the CBSX TPH to become a
member of FINRA.\14\
---------------------------------------------------------------------------
\12\ As of December 20, 2013, 38 CBSX TPHs would be affected by
this eligibility requirement (i.e., are not already members of
FINRA).
\13\ The Exchange will also issue periodic written reminders to
all CBSX TPHs affected by this requirement that the CBSX TPH must
become a FINRA member by the Compliance Date.
\14\ The Exchange notes that the ability to extend certain time
limits where extenuating circumstances exist is consistent with and
similar to other Exchange rules. See e.g., CBOE Rule 3.19 and CBOE
Rule 3.30.
---------------------------------------------------------------------------
[[Page 8772]]
III. Discussion of Comment Letters, CBOE's Response, and Commission
Findings
After careful review and for the reasons discussed below, the
Commission finds that the proposed rule change is consistent with the
requirements of the Act, including Section 6 of the Act,\15\ and the
rules and regulations thereunder applicable to a national securities
exchange.\16\ In particular, the Commission finds that the proposed
rule change is consistent with Section 6(b)(5) of the Act,\17\ which
requires, among other things, that the rules of a national securities
exchange be designed to prevent fraudulent and manipulative acts and
practices, to promote just and equitable principles of trade, and, in
general, to protect investors and the public interest, and not be
designed to permit unfair discrimination between customers, issuers,
brokers, or dealers. In addition, the Commission finds that the
proposal is consistent with Section 6(b)(2) of the Act,\18\ which
requires that the rules of a national securities exchange provide that
any registered broker or dealer may become a member of such exchange.
The Commission also finds that the proposed rule change is consistent
with Section 6(b)(8) of the Act,\19\ which requires that the rules of a
national securities exchange not impose any burden on competition not
necessary or appropriate in furtherance of the purposes of the Act.
---------------------------------------------------------------------------
\15\ 15 U.S.C. 78f.
\16\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\17\ 15 U.S.C. 78f(b)(5).
\18\ 15 U.S.C. 78f(b)(2).
\19\ 15 U.S.C. 78f(b)(8).
---------------------------------------------------------------------------
The Commission received four comment letters on the proposed rule
change.\20\ All four commenters object to the proposed rule change,
argue that it is inconsistent with the Act, and recommend that CBOE
either enter into a regulatory services agreement or a Rule 17d-2 \21\
plan with FINRA. In response, CBOE states that none of the comments
provide a basis for disapproval of the proposal and reiterates its
position that the proposal meets the standards for approval under the
Act.\22\ The comments, CBOE's response, and the Commission's findings
are discussed in detail below.
---------------------------------------------------------------------------
\20\ See supra, note 5.
\21\ 17 CFR 240.17d-2.
\22\ See CBOE Letter.
---------------------------------------------------------------------------
A. Statutory Requirements for Exchange Membership
Two commenters \23\ argue that the proposed rule change violates
Section 6(b)(2) of the Act \24\ because the proposal would impose
requirements for exchange membership beyond those contained in the Act.
Section 6(b)(2) of the Act provides that ``[a]n exchange shall not be
registered as a national securities exchange unless the Commission
determines that . . . subject to the provisions of subsection (c) of
this section, the rules of the exchange provide that any registered
broker or dealer . . . may become a member of such exchange. . .'' \25\
The two commenters state that the proposal violates Section 6(b)(2)
because it effectively denies or excludes certain registered broker-
dealers from membership (TPH status) with CBSX.\26\ One of the
commenters asserts that CBOE incorrectly interprets Section 6(b)(2) as
permitting it to exclude certain registered broker-dealers based on
their affiliation with certain other self-regulatory organizations
(``SROs'').\27\ The other commenter points to Section 6(c) of the
Act,\28\ which provides specific reasons for which a registered broker-
dealer may be prohibited from becoming a member of an exchange, as
further evidence that the proposal is in violation of Section 6(b)(2)
of the Act.\29\ The commenter notes that none of the bases in Section
6(c) permit an exchange to deny membership to a broker-dealer solely on
the basis of not being a member of a national securities
association.\30\
---------------------------------------------------------------------------
\23\ See Virtu Letter and FIA Letter.
\24\ 15 U.S.C. 78f(b)(2).
\25\ Section 6(c) of the Act provides bases for denial of
membership in a national securities exchange, including failure to
register as a broker-dealer, statutory disqualification, or failure
to meet the standards of financial responsibility or operational
capacity, or a showing that the party has or that there is a
reasonable likelihood that they may engage in acts or practices
inconsistent with just and equitable principles of trade.
\26\ See Virtu Letter, at 2; FIA Letter, at 3-4.
\27\ See Virtu Letter, at 2.
\28\ 15 U.S.C. 78f(c).
\29\ See FIA Letter, at 3-4.
\30\ Id.
---------------------------------------------------------------------------
In response, CBOE states that it is incorrect to infer from these
statutory provisions that any registered broker-dealer meeting the
general requirements of Section 6(b)(2) and that does not fall within
the categories enumerated in Section 6(c) is always entitled to
membership.\31\ CBOE notes that the rules of national securities
exchanges virtually always provide bases for denial of membership in
addition to those enumerated in Section 6(c) of the Act.\32\ CBOE also
notes that other national securities exchanges have membership with
another national securities exchange or national securities association
as a condition for membership.\33\
---------------------------------------------------------------------------
\31\ See CBOE Letter, at 3.
\32\ Id.
\33\ See CBOE Letter, at 3-4. CBOE also noted that former NYSE
Rule 2(b) required membership in FINRA as a condition precedent to
becoming or remaining a member organization. Id., at 4.
---------------------------------------------------------------------------
The Commission believes that the proposed rule change is consistent
with Section 6(b)(2) and Section 6(c) of the Act. While Section 6(c)
specifies certain bases upon which a national securities exchange can
deny membership to, among other entities, a broker or a dealer, Section
6(c) is not intended to provide an exclusive list of reasons a national
securities exchange can deny membership to a party. National securities
exchanges may have requirements for exchange membership beyond those
contained in the Act so long as they are consistent with the Act.\34\
For example, the Commission has approved the rules of several national
securities exchanges that require membership with another SRO as a
condition of membership.\35\ The Commission believes that CBOE's
proposal requiring CBSX TPHs to be members of FINRA, another SRO, is
consistent with Section 6(b)(2) and Section 6(c) of the Act.
---------------------------------------------------------------------------
\34\ See e.g. CHX Article 3; Rules of BATS Exchange, Chapter II;
Nasdaq Stock Market Rule 1000 series.
\35\ See supra, note 9.
---------------------------------------------------------------------------
B. Discrimination Among CBOE Members
Two commenters assert that the proposal violates Section 6(b)(5)
\36\ by discriminating against CBSX TPHs.\37\ Section 6(b)(5) provides,
among other things, that the rules of an exchange must not be designed
to permit unfair discrimination between customers, issuers, brokers, or
dealers. One commenter states that the proposal results in certain CBOE
members that are not FINRA members being denied access to CBSX (CBOE's
exchange facility for equities), while other CBOE members that are not
FINRA members will continue to have access to the CBOE options
facility, thus effectively discriminating against members that trade
equities.\38\ The other commenter shares the same concern and states
that this disparate treatment is impermissible under the Act.\39\
---------------------------------------------------------------------------
\36\ 15 U.S.C. 78f(b)(5).
\37\ See Virtu Letter; CHX Letter.
\38\ See Virtu Letter, at 2.
\39\ See CHX Letter, at 3.
---------------------------------------------------------------------------
[[Page 8773]]
CBOE responds to these concerns by stating that Section 6(b)(5)
requires only that exchange rules be designed not to permit unfair
discrimination and that CBOE may impose ``requirements on a subgroup of
members who elect to avail themselves of specified exchange services or
who conduct specified types of business,'' while not imposing such
requirements ``on other members who choose not to use such services or
conduct such types of business, or otherwise where such additional
requirements would serve a valid regulatory purpose.'' \40\ The
Exchange argues that the proposed rule is justified by the need for
greater regulatory oversight of the away trading activity of CBSX TPHs.
Because away trading activity does not occur on the CBSX market, CBOE
states that it does not have access to all the necessary order and
trade information for this trading activity with which to directly
conduct systematic surveillance reviews relating to this trading
activity.\41\ CBOE believes that because FINRA's rules require each
FINRA member to submit order data for its trading activity on all
trading venues on a regular basis, FINRA has greater access to off-
exchange trading activity conducted by its members than do national
securities exchanges.\42\ Therefore, CBOE believes that its proposal to
require FINRA membership of CBSX TPHs is reasonably designed to enhance
regulatory oversight of CBSX TPHs so it does not unfairly discriminate
among CBOE TPHs, but rather imposes a reasonable additional obligation
on those CBOE TPHs who choose to be CBSX TPHs as well.\43\
---------------------------------------------------------------------------
\40\ See CBOE Letter, at 6.
\41\ Id.
\42\ Id., at 6-7. CBOE also explains that, as a member of the
Intermarket Surveillance Group, CBOE receives an equity audit trail
of all equity market orders and trade information for away trading
activity, but that the audit trail does not provide the necessary
granular level of detail to denote when a CBSX TPH is executing a
trade as a customer through another broker-dealer on an away market.
CBOE states that without such granular information, the Exchange is
limited in the reviews it can conduct of this activity. Id., at 6,
note 22.
\43\ Id., at 7.
---------------------------------------------------------------------------
The Commission believes that the proposal is consistent with
Section 6(b)(5) of the Act. The Commission believes that the proposal
does not unfairly discriminate against CBSX TPHs. As CBOE stated,
Section 6(b)(5) does not prevent an exchange from imposing additional
requirements on a subgroup of members who elect to avail themselves of
specified exchange services or who conduct certain types of business.
Here, CBOE's proposal to require CBSX TPHs to be members of FINRA while
not requiring CBOE TPHs to be members of FINRA is not unfairly
discriminatory because it will apply equally to all CBSX TPHs and
enhance the regulatory oversight of CBSX TPHs' trading activity.
C. Cost
Three commenters argue that the proposed rule change imposes a
substantial cost on CBSX TPHs by requiring dual membership with
FINRA.\44\ One commenter believes that the proposal will make it
prohibitively expensive for some CBSX TPHs to continue to hold CBSX
trading permits or become members of other exchanges, thereby imposing
a burden on competition not necessary or appropriate in furtherance of
the purposes of the Act in violation of Section 6(b)(8).\45\ The
commenter argues that CBSX TPHs that are proprietary trading firms that
do not carry public customer accounts would be required to bear the
same costs of FINRA membership as CBSX TPHs that carry public customer
accounts.\46\ The commenter further states that the ``burdens on
competition are not appropriate because [s]ection 17(d) of the Act
provides the mechanism through which an SRO could share certain
regulatory responsibilities with other SROs . . .'' \47\ Another
commenter criticizes the proposal stating that dual FINRA membership
places a large burden on members including, but not limited to, an
additional layer of regulatory costs and being subject to compliance
with FINRA rules, which have no relevance to proprietary traders who do
not have public customers.\48\
---------------------------------------------------------------------------
\44\ See Gusrae Nusbaum Kaplan Letter, CHX Letter, and FIA
Letter.
\45\ See CHX Letter, at 2-3.
\46\ Id., at 3.
\47\ Id.
\48\ See Gusrae Nusbaum Kaplan Letter, at 2.
---------------------------------------------------------------------------
A third commenter points out that ``undertaking FINRA membership is
a significant, time-consuming and expensive exercise.'' \49\ The
commenter explains that FINRA membership would require firms (1) to
review and analyze the applicability of a vast array of rules and
interpretations from FINRA, the majority of which are designed for
firms that transact customer business; (2) to amend filings with other
exchanges, incurring additional unnecessary filing costs; (3) to
maintain blanket fidelity bond coverage, which the commenter states is
typically designed to insure a firm against intentional fraudulent and
dishonest acts involving customer funds or customer accounts, while the
firms affected by the proposed rule change do not transact customer
business; (4) to incur the costs of reporting to FINRA's order audit
trail system; and (5) to require their associated persons to pass
additional exams, since certain exams (such as the Series 56) are not
recognized by FINRA.\50\ The commenter states that if this proposed
rule goes into effect, CBSX would be the only exchange requiring FINRA
membership for member firms that do not transact customer business and
therefore would position CBSX as an outlier and subject to possible
regulatory arbitrage, which could increase market fragmentation.\51\
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\49\ See FIA Letter, at 4.
\50\ Id., at 4-5.
\51\ Id., at 6.
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In response to these concerns, CBOE states that any CBSX TPH that
finds it burdensome to become a FINRA member can resign its CBSX
membership and become a member of a national securities exchange that
does not require membership with FINRA.\52\ CBOE states, ``[t]here are
any number of national securities exchanges that would provide the
alternative, so the Proposal imposes no burden on competition that a
CBSX TPH cannot easily eliminate if it chooses.'' \53\ CBOE also states
that if a CBSX TPH cannot comply with the proposal by the Compliance
Date due to extenuating circumstances, CBOE may permit the CBSX TPH to
retain its status as a TPH for a time CBOE deems reasonably necessary
for the CBSX TPH to become a member of FINRA.\54\ Regarding dual
registration, CBOE notes that other national securities exchanges
require membership in another SRO.\55\ Further, according to the
Exchange, CBSX TPHs that do not conduct a public customer business
would be subject only to those FINRA rules that were applicable to
their business.\56\ CBOE also notes that if associated persons of CBSX
TPHs are currently licensed in a registration category that FINRA does
not recognize, FINRA's rules permit FINRA to waive its licensing
requirements and accept other standards for qualifying for
registration.\57\
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\52\ See CBOE Letter, at 9.
\53\ Id.
\54\ Id., at 10.
\55\ Id., at 9.
\56\ Id., at 11.
\57\ See CBOE Letter, at 11.
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The Commission believes that the proposal is consistent with
Section 6(b)(8) of the Act and does not impose any burden on
competition not necessary or appropriate in furtherance of the purposes
of the Act. As CBOE stated, any firm that determines not to become a
FINRA member can join another national securities exchange
[[Page 8774]]
that does not require FINRA membership. The Commission, as noted above,
has approved the membership rules of several exchanges that require
membership with another SRO as a condition of membership.\58\
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\58\ See supra, note 9.
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D. Section 15(b)(8) of the Act and Rule 15b9-1 Thereunder
One commenter \59\ argues that the proposal conflicts with Section
15(b)(8) of the Act \60\ and Rule 15b9-1 thereunder.\61\ Section
15(b)(8) of the Act prohibits a registered broker or dealer from
effecting a transaction in a security unless the broker or dealer is a
member of a national securities association or effects transactions in
securities solely on a national securities exchange of which it is a
member. Rule 15b9-1(a) exempts a broker or dealer from becoming a
member of a national securities association if it: (1) Is a member of a
national securities exchange; (2) carries no customer accounts; and (3)
has annual gross income of no more than $1,000 that is derived from
securities transactions otherwise than on an exchange of which it is a
member.\62\ The commenter believes that the proposed rule change
conflicts with these provisions because it would require all CBSX
TPHs--even those that would qualify for the Rule 15b9-1 exemption--to
become members of a national securities association.\63\ The commenter
states this directly contradicts Rule 15b9-1, which recognizes that
certain broker-dealers should not be required to become members of a
national securities association.\64\
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\59\ See CHX Letter, at 2.
\60\ 15 U.S.C. 78o(b)(8).
\61\ 17 CFR 240.15b9-1.
\62\ Rule 15b9-1(b) states that the gross income limitation in
(a) does not apply to income derived from transactions (1) for the
dealer's own account with or through another registered broker or
dealer or (2) through the Intermarket Trading System.
\63\ See CHX Letter, at 2.
\64\ Id.
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In its response, CBOE states that neither Section 15(b)(8) nor Rule
15b9-1 preclude CBOE from adopting a more restrictive rule concerning
when a member must become a member of a national securities
association.\65\ In fact, CBOE claims that exchanges often impose
requirements on their members that are stricter than those specifically
enumerated in the Exchange Act and Commission rules.\66\ CBOE believes
that Rule 15b9-1 ``has no application if the requirement to become a
member of a national securities association is required not by Section
15(b)(8) of the [Act], but by some other authority, such as an exchange
rule.'' \67\
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\65\ See CBOE Letter, at 5.
\66\ Id.
\67\ Id.
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The Commission does not believe that the proposed rule change
conflicts with Section 15(b)(8) or Rule 15b9-1. As CBOE stated,
national securities exchanges may impose requirements on their members
that are more stringent than those imposed by the Act or by Commission
rules. Therefore, the requirement imposed by proposed Rule 50.4A that
CBSX TPHs become members of FINRA, although more restrictive than
Section 15(b)(8), is consistent with the Act and not in violation of
Section 15(b)(8) or Rule 15b9-1.
E. Satisfaction of Regulatory Obligations
One commenter \68\ believes that the proposed rule change is an
admission of CBOE's failure to satisfy its exchange obligations, in
violation of Section 6(b)(1) of the Act, which requires an exchange to,
among other things, enforce compliance by its members with provisions
of the Act and the rules thereunder.\69\ The commenter argues it is not
appropriate for an exchange to alter its membership requirements in
order to satisfy its regulatory burden and that if CBOE fails to
satisfy its regulatory responsibilities, then CBOE's status as an
exchange and its ability to operate the CBSX must be scrutinized.\70\
This commenter and another commenter observe that the issue of CBOE not
having access to all necessary order and trade information for away
trading activity is not unique to CBOE, yet other exchanges have been
able to fulfill their exchange obligations regardless.\71\
Specifically, the other commenter argues that other exchanges have not
shifted the costs associated with surveillance and monitoring to
certain of its member firms by imposing a burdensome new membership
requirement at FINRA in order to discharge their regulatory
obligations.\72\ A third commenter states that the proposal is an
inefficient attempt by the CBOE to remedy a fundamental break down in
its regulatory structure, that instead of building up its own
surveillance and enforcement departments and abilities, the CBOE is
shifting the burden entirely onto its members and FINRA.\73\ Finally, a
fourth commenter states that it is concerned with the precedent that
will be set if the proposal is approved, specifically that an SRO will
be permitted to adopt rules that will unilaterally shift some of its
responsibilities to another SRO.\74\
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\68\ See Virtu Letter, at 1, 3.
\69\ 15 U.S.C. 78f(b)(1). Section 6(b)(1) of the Act states that
``[a]n exchange shall not be registered as a national securities
exchange unless the Commission determines that . . . [s]uch exchange
is so organized and has the capacity to be able to carry out the
purposes of this title and to comply, and . . . to enforce
compliance by its members and persons associated with its members,
with the provisions of this title, the rules and regulations
thereunder, and the rules of the exchange.''
\70\ See Virtu Letter, at 3.
\71\ Id. and FIA Letter, at 6.
\72\ See FIA Letter, at 6.
\73\ See Gusrae Kaplan Nusbaum Letter, at 2.
\74\ See CHX Letter, at 1.
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All four commenters suggest that a better resolution would be for
CBOE to enter into a Rule 17d-2 plan or a regulatory services agreement
with FINRA in lieu of the proposed rule change.\75\ One commenter
recommends that CBOE either adopt a rule requiring its members to send
their trading activity data to FINRA, or that CBOE enter into a
regulatory services agreement with FINRA allowing FINRA to collect this
data and surveil it.\76\ The other commenters were in favor of CBOE
entering into Rule 17d-2 plan.\77\
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\75\ See Virtu Letter, at 1-2; Gusrae Kaplan Nusbaum Letter, at
3; CHX Letter, at 3; and FIA Letter, at 6.
\76\ See Gusrae Kaplan Nusbaum Letter, at 3.
\77\ See Virtu Letter, at 1-2; CHX Letter, at 3; and FIA Letter,
at 6.
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In response, CBOE reiterates that the proposal is designed to
enhance the regulation of CBSX.\78\ CBOE explains that it does not have
access to all of the necessary order and trade information for away
trading activity and that the proposal addresses this limitation on its
ability to oversee away trading activity.\79\ CBOE further explains
that entering into a 17d-2 agreement with FINRA is not possible to
address the away trading activity of CBSX TPHs because a 17d-2
agreement is available only with respect to broker-dealers that are
members of each SRO that is a party to the agreement, and by
definition, the proposal addresses the situation in which CBSX TPHs are
not FINRA members.\80\ CBOE acknowledges that there may be other ways
to accomplish its regulatory goal, but that it has determined that its
proposal is a reasonable method of achieving its regulatory
objectives.\81\ CBOE also reiterates its position that its proposal is
consistent with the Exchange Act and notes that this is further
evidenced by the fact that the Commission has previously approved
exchange rules requiring members to be members of at least one other
SRO.\82\
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\78\ See CBOE Letter, at 7.
\79\ Id.
\80\ Id., at 7-8.
\81\ Id., at 8.
\82\ Id. CBOE also stated that because other exchanges also
require their members to be members of at least one other SRO, it is
evident that its proposal does not reflect that it is in violation
of Section 6(b)(1). Id., at note 25.
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[[Page 8775]]
The Commission does not believe that CBOE's proposal, in and of
itself, provides evidence that CBOE has failed to meet its exchange
obligations. The Commission also notes that CBOE's proposal in no way
(1) reduces CBOE's obligations under the Act to meet its regulatory
responsibilities as an SRO, or (2) shifts any of CBOE's
responsibilities to FINRA. The Commission agrees with CBOE that a Rule
17d-2 plan is available as an option only with respect to broker-
dealers that are members of each SRO that is a party to the agreement.
CBOE has proposed to require CBSX members to be members of FINRA in
order to enhance regulation of their away trading activity. Whether or
not there may be other less costly or burdensome ways to enhance
regulation of away trading activity by CBSX members, the issue before
the Commission is whether the current proposal is consistent with the
Exchange Act and the rules and regulations thereunder applicable to
SROs. If so, the Commission must approve the proposed rule change. The
Commission believes that the proposal is consistent with the Act. As
stated above, exchanges may impose membership requirements that are
more stringent than those contained in the Act. The Commission has
previously approved rules of other exchanges requiring membership in
another SRO.
IV. Conclusion
For all the reasons discussed above, the Commission finds that the
proposed rule change is consistent with the requirements of the Act and
the rules and regulations thereunder applicable to national securities
exchanges. It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\83\ that the proposed rule change (SR-CBOE-2013-100) be, and it is
hereby approved.
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\83\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\84\
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\84\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-03132 Filed 2-12-14; 8:45 am]
BILLING CODE 8011-01-P