Cboe Speeds Up Complex Trade Bids: Yawn-Worthy Update
Published Date: 8/18/2025
Notice
Summary
Cboe Exchange is updating its rules to make it easier for market-makers to submit bids and offers for complex trading strategies using a bulk message system. This change helps speed up trading and encourages more market activity. The new rules took effect right away on August 12, 2025, with no extra costs for traders.
Analyzed Economic Effects
8 provisions identified: 5 benefits, 2 costs, 1 mixed.
Bulk Messages Can Include Complex Strategies
As of August 12, 2025, the Exchange allows Market-Makers to submit bulk messages that include bids and offers for Exchange-designated complex strategies, letting a Market-Maker enter, modify, or cancel multiple complex bids and offers in a single electronic message. The Exchange says this expansion is intended to encourage provision and consolidation of liquidity in those designated complex strategies.
Complex Bulk Messages Must Be Post Only and Can't Leg
Complex bulk messages and complex orders submitted through bulk ports must be designated Post Only, meaning they may not remove displayed liquidity. A complex bid or offer submitted in a bulk message is not eligible to initiate a complex order auction (COA) and will not leg into the simple book for execution.
Complex Bulk Messages Limited to Day Time‑in‑Force
The rule requires that bulk messages comprised of complex bids and offers must have a Time-in-Force of Day. Separately, orders submitted through bulk ports must be designated as Day or Good‑til‑Date (GTD) where the GTD date must be the date the order was entered.
IOC Not Allowed for Complex Bulk Messages
The Exchange does not permit Immediate‑or‑Cancel (IOC) designations on complex bulk messages. The IOC designation on simple quotes remains permissible only for appointed Market‑Makers in their appointed classes.
MTP Modifiers Allowed for Complex Bulk Ports
Market‑Makers may set the same match trade prevention (MTP) default modifiers for complex bulk messages that are permitted for simple bulk messages: MTP Cancel Newest (MCN), MTP Cancel Oldest (MCO), or MTP Cancel Both (MCB), and set a default attributable or non‑attributable value for a bulk port. Those defaults apply to all bulk messages on that port.
Users May Submit Complex Orders Through Bulk Ports
All Users (not just Market‑Makers) may submit single complex orders through bulk ports in the same manner they submit complex orders through other ports. Complex orders submitted through bulk ports must be designated Day or GTD (date must be the date entered) and must be Post Only when submitted through a bulk port.
Fat‑Finger Check Applied to Complex Bulk Messages
The Exchange moved the bulk-message fat‑finger price check so it applies to bulk messages containing simple or complex bids and offers, and for complex bulk messages the check references the synthetic national best bid or offer (SNBBO). The check otherwise operates the same as it does for simple bulk messages.
Complex Bulk Messages Treated as Quotes for CAT Reporting
Complex bulk messages will be reported to the Consolidated Audit Trail (CAT) in the same manner as simple quotes: Options Market‑Makers do not have to send quote data to CAT for bulk messages but must include a quote sent time, which the Exchange will report to CAT. Market‑Makers must continue to send data for complex order messages directly to CAT.
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