Subject: SR-CBOE-2011-100

November 30, 2011

There is no need to implement SR-CBOE-2011-100. The closing time of the SPX expiring options has been 3:15 PM for many years. There is no logical reason to change the time to 3:00PM.

Anyone who has on a time spread will not be able to exit the spread OR roll the spread after 3:00.

Please do not implement this rule change.