To Whom It May Concern:
CTC, LLC is a member firm of the Chicago Board Options Exchange ("CBOE").
It is the Designated Primary Market Maker ("DPM") for twelve ETF options products at one DPM post and the Spider options at another post. CTC's DPM listings are U.S. equity based index products that are traded mostly by institutions.
For the most part, CTC endorses this rule filing and agrees with its purpose and intent. However, we suggest that it initially be approved as a three month pilot to give the CBOE community some working experience before the rule becomes finalized. There are currently a few basic operational considerations that are still unknown. For example, the mechanics of how linkage orders will be booked into a DPM account is being addressed now.
There are a couple of other nuances that dovetail into the membership rules and procedures and COATS regulations. Implementation of this rule will require modifications to the CBOE systems. A three month pilot would make it easier to tweak the proposed rule should modifications be necessary to take into consideration operational constraints. Since any amendments to the proposed rule would still be subject to SEC approval, this suggestion would not undermine the main objective of the proposed rule. It would only make any amendments, that the CBOE and SEC agree are necessary, administratively easier.
Thank you for your consideration.
Chief Operations & Compliance Officer
141 W. Jackson Blvd.
Chicago, IL 60604