Cboe Updates Disqualification Rules: Keeping Bad Actors Out, Bureaucracy In
Published Date: 4/27/2026
Notice
Summary
Cboe Exchange is updating its rules for Trading Permit Holders and their associates who face legal disqualifications, making sure the rules match those of other financial regulators. This change affects anyone holding or linked to a trading permit and takes effect immediately, helping keep the market fair and trustworthy without extra costs. If you’re involved, pay attention now to stay in the game!
Analyzed Economic Effects
3 provisions identified: 2 benefits, 0 costs, 1 mixed.
Rules Harmonize With FINRA
If you are a Trading Permit Holder (TPH) or an associated person of a TPH, the Exchange is changing its Rule 3.13 to align with FINRA's eligibility procedures. The change is intended to prevent different outcomes for firms that are members of both the Exchange and FINRA and to make compliance less burdensome for dual members.
Fewer 19h-1 Notices Required
The Exchange will in large part adopt FINRA-style procedures and rely on the FINRA No-Action Letter (March 17, 2009) and FINRA processing to determine when a 19h-1 Notice must be filed. As a result, the filing notes that fewer 19h-1 Notices will be required and that TPHs or associated persons may not need to submit applications for prior statutory disqualifications that have been resolved.
Exchange Keeps Its Own Fee Practice
The Exchange will not adopt FINRA's statutory-disqualification application fee refund practice (FINRA retains $1,000 as a processing fee) and instead will apply its own application fee program as reflected in the Exchange's fee schedule. That means applicants will be subject to the Exchange's separate fee rules rather than FINRA's fee refund language.
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Key Dates
Department and Agencies
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