Cboe Simplifies Audit Submission Rules for Traders
Published Date: 8/29/2025
Notice
Summary
Cboe Exchange is updating its rules to make it clearer and easier for Trading Permit Holders to submit their yearly audited financial reports. This change affects all Trading Permit Holders and requires them to follow a specific federal rule when sending in their audits. The new rules are effective immediately, helping keep things transparent without adding extra costs or delays.
Analyzed Economic Effects
5 provisions identified: 4 benefits, 1 costs, 0 mixed.
All Trading Permit Holders Must File Annual Audits
The Exchange now requires every Trading Permit Holder (TPH) to submit an annual audited report to the Exchange in accordance with SEC Rule 17a-5(d). This change applies to all TPHs, including the five TPHs (of 94) that previously relied on the exemption in Rule 17a-5(d)(1)(iv) and did not file audited reports with the Exchange.
Filing Deadline Aligned to 60 Days After Fiscal Year
The Exchange has aligned Rule 7.4(a) with SEC Rule 17a-5 so annual reports must be filed no more than 60 calendar days after a TPH's fiscal year end. The rule clarifies that the scope of information required matches Rule 17a-5(d) and Form X-17A-5.
Accountant Notification Deadline Moved to December 10
The Exchange aligned its deadline for TPHs to notify the Exchange of the name of their independent public accountant with SEC Rule 17a-5(f)(2), requiring that statement no later than December 10 of each year (or 30 days after registration if earlier). This replaces the prior January 10 notification date in Exchange rules.
Exchange Deletes Substitute-Filing Exception
The proposed rule deletes the prior Exchange exception that allowed a TPH to submit, in lieu of the required report, a copy of a financial statement filed with another national securities exchange or state agency. The Exchange states this exception is unnecessary because TPHs must comply with the Act's Form X-17A-5 requirement.
Extensions Allowed for Exceptional Circumstances
If the Exchange is a TPH's designated examining authority (DEA) and a TPH cannot meet the filing deadline for annual audits due to exceptional circumstances, the TPH may request a written extension from the Exchange. The Exchange will also recognize extensions or exemptions granted by the Commission or the TPH's DEA.
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