Cboe Widens Fingerprint Checks for Exchange Insiders
Published Date: 9/25/2025
Notice
Summary
Cboe Exchange is updating its rule to improve fingerprint-based background checks for its directors, officers, employees, and contractors. This change means more people connected to the Exchange will get these checks faster and more efficiently. The new rule is effective immediately, with no extra costs expected for those involved.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 2 costs, 1 mixed.
Fingerprinting required for Exchange insiders
The Exchange's amended Rule 7.10 requires that the Exchange's partners, directors, officers, and employees be fingerprinted and have those fingerprints submitted for identification and processing under Section 17(f)(2) of the Securities Exchange Act. This requirement is in the amended rule that became operative upon filing on September 9, 2025.
Contractors removed from fingerprint list
The Exchange deleted references to temporary personnel, independent contractors, consultants, vendors, and service providers (collectively, "Contractors") from the list of parties required to be fingerprinted under Rule 7.10, aligning the rule with Section 17(f)(2) which references partners, directors, officers, and employees. That change was made in the amendment effective upon filing on September 9, 2025.
Employer background checks for unescorted contractors
Although Contractors were removed from the Exchange's fingerprint requirement, the amended Rule 7.10 requires that any Contractor who has or is anticipated to have unescorted access to Exchange facilities and records must have been subject to a background screening process by their employer. This requirement is codified in the amended rule that became operative upon filing on September 9, 2025.
Rule change effective immediately upon filing
The Commission waived the usual 30-day operative delay and designated the Exchange's proposed amendment to Rule 7.10 as operative upon filing. The filing date for the proposed rule change was September 9, 2025, so the amendments became operative on that date.
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