Sep. 29, 2023
Dear SEC, We believe it is in the best interest of the public for the SEC to approve the FLEX Equity Option order type on the BOX Options exchange. Our organization owns and operates various floor-brokerage operations with memberships at every exchange with a physical floor presence (ARCA, AMEX, CBOE, BOX, PHLX). As an organization that has extensive experience trading FLEX Equity Options at every on-floor venue, we feel strongly about permitting the BOX to offer FLEX Equity Options for the following reasons: 1) Executing FLEX Equity Options is available on all other floor operations (AMEX, ARCA, CBOE, and PHLX) and the BOX is unique in not having this order type available. Permitting the BOX to offer FLEX will expand competition and thus drive better execution experiences for the public. 2) To further our thoughts on the first bullet point, in our estimation BOX has been a strong innovator as it relates to open-outcry execution of listed options since their inception less than a decade ago. This has in turn pushed other exchanges to improve their execution experience as well. We believe something similar can happen here as well with FLEX. FLEX Equity Option execution quality on-floor at the various exchanges is currently very manual, takes considerably more time than a listed options trade, and does not leverage present-day technology well. An infusion of competition will be more than welcome and have a potentially virtuous effect on the whole on-floor industry thus benefiting the public. 3) The demands from the public for execution services relating to broader complex option strategies including FLEX are only growing; as such, expanding capacity would only benefit the public.