Proposed Rule Change To Increase Position Limits for Options on Certain Exchange-Traded Funds and Indexes

Published on:
April 6, 2020
Submitted to:
SEC
Submitted by:
SIFMA
File Number:
SR–CBOE–2020–015

Summary

SIFMA provided comments to the Securities and Exchange Commission on a proposed rule change made by Cboe Exchange, Inc. In the Filing, Cboe proposes to amend Exchange Rules 8.30 and 8.31, Position Limits, to increase the position limits for options on six (6) underlying Exchange Traded Funds (ETF) as well as two Indexes (the “Indexes”) (together, the “Proposal”).

Excerpt

April 6, 2020

Ms. Vanessa Countryman

Secretary

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Cboe Exchange, Inc.; Notice of Filing of a Proposed Rule Change To Increase Position Limits for Options on Certain Exchange-Traded Funds (‘‘ETFs’’) and Indexes (File No. SR–CBOE–2020–015)

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment upon the above-referenced filing (the “Filing” or the “Cboe Filing”) made by Cboe Exchange, Inc. (“Cboe” or “Exchange”) with the Securities and Exchange Commission (“SEC” or the “Commission”). In the Filing, Cboe proposes to amend Exchange Rules 8.30 and 8.31, Position Limits, to increase the position limits for options on six (6) underlying Exchange Traded Funds (“ETFs”) as well as two Indexes (the “Indexes”) (together, the “Proposal”).

SIFMA recommends that the Commission approve Cboe’s Proposal to increase the position limits for the options on the ETFs and Indexes as set forth therein, and respectfully submits this comment letter in response to the SEC’s solicitation of comments. As discussed below, SIFMA believes that the arguments underlying Cboe’s Proposal support its approval by the Commission as it relates to the symbols referenced in filing SR-CBOE-2020-15.

As an initial matter, SIFMA observes that Cboe’s analysis is correct with respect to the continuously increasing market capitalization of the Underlying ETFs, the ETF component securities, and the component securities of the Underlying Indexes, under normal market conditions. This market capitalization should mitigate any concern about potential manipulation and/or disruption in the underlying markets upon increasing position limits.2 Cboe’s arguments are also accurate with respect to the highly liquid markets for the underlying securities, even to the extent that trading in such securities is presenting somewhat differently during the current market volatility The rising demand for trading options on the Underlying ETFs and Indexes suggests legitimate market need for an increase in position limits. As Cboe observes, increasing position limits would enable liquidity providers to provide additional liquidity to the Exchange, and enable other market participants to transfer their liquidity demands from OTC markets to the Exchange and other options exchange on which they participate. Conversely, as Cboe correctly points out, failing to adjust position limits for options on these ETFs and Indexes will likely continue to impede trading activity and strategies of investors, such as use of effective hedging vehicles or income generating strategies, and the ability of Market-Makers to make liquid markets with tighter spreads in these options.

Continue Reading

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.