Cboe C2 Charges Traders for Unbilled Past Audit Fees
Published Date: 5/14/2026
Notice
Summary
Cboe C2 Exchange is updating its fee schedule to charge Industry Members for some past costs related to the Consolidated Audit Trail that weren’t billed before January 1, 2022. This means certain members will see new fees starting right away to cover these historical expenses. The change is effective immediately, so affected members should be ready for the updated charges.
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Analyzed Economic Effects
3 provisions identified: 0 benefits, 3 costs, 0 mixed.
Industry Members Billed $38.96M
The Exchange will charge Industry Members (CAT Executing Brokers: CEBBs and CEBSs) a Historical CAT Assessment 1A to recover $38,964,855.34 of past Consolidated Audit Trail costs that were not invoiced before. The outstanding amount is split equally so CEBBs will be charged $19,482,427.67 and CEBSs will be charged $19,482,427.67, effective immediately after the filing on April 27, 2026.
Per-Share Fee Rate Set at $0.000002
The Operating Committee set the Historical CAT Assessment 1A fee rate at $0.000002. Each monthly Historical CAT Assessment for a transaction is calculated by multiplying the number of executed equivalent shares by one-third and by the Historical Fee Rate (i.e., executed equivalent shares × 1/3 × $0.000002). Executed equivalent shares count NMS stock shares as 1, listed options contracts by their multiplier (e.g., 100), and OTC equity shares as 0.01.
Brokers May Pass-Through Fees To Customers
The Commission recognized that Industry Members may pass-through CAT fees for customer executed volume. That means if your broker is charged these Historical CAT Assessment fees, they may pass some or all of the cost to you based on the $0.000002 fee rate and the executed-equivalent-share calculation.
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