Regulatory Circular RG14-171

Regulatory Circular RG14-171 Date: December 10, 2014 To: Trading Permit Holders From: Regulatory Services Division RE: Implementation Date for the Stock Order Marking and Requirements This Regulatory Circular updates Regulatory Circular RG14-110. Chicago Board Options Exchange, Incorporated (the Exchange ) rule change SR-CBOE-2014-040 that, among other things, requires each Trading Permit Holder ( TPH ) to, on the business day following the order execution date, report to the Exchange certain information regarding the executed stock or convertible security legs of Qualified Contingent Cross ( QCC ) orders, stock-option orders and other Tied to (as defined below) that the TPH executed on the Exchange that trading day was approved on August 1, 2014. Approved Rule 15.2A sets forth the reporting requirements for. The manner and form of these reports will follow the data layout requirements set forth in the attachment to this Regulatory Circular. These requirements are a component of data layout requirements for other regulatory requested data submissions. As a result, there are references in the layout not directly applicable to the tied to stock reporting requirement. (See the Required for Stock column for identification of the applicable fields). If the Exchange determines to update or change these data layout requirements, it will announce those updates or changes in another Regulatory Circular. Each TPH must report to the Exchange the following information: (a) time of execution; (b) execution quantity; (c) execution price; (d) venue of execution; and (e) any other information requested by the Exchange. Pursuant to Rule 15.2A, a TPH may arrange for its clearing firm to submit these reports on its behalf; however, if the clearing firm does not report an executed stock order, the TPH retains the reporting responsibility. Additionally, TPHs do not need to report information pursuant to CBOE Rule 15.2A with respect to: (a) stock-option orders submitted to the Exchange for electronic processing or (b) stock or convertible security orders entered into an Exchange-approved device, e.g. Floor Broker Work Station ( FBW ). TPHs registered as CBOE Market-Makers (or their clearing firms) may include the information required by CBOE Rule 15.2A in the equity reports submitted pursuant to existing CBOE Rule 8.9(b). Thus, Market-Makers currently do not need to submit additional information to satisfy the reporting requirement in Rule 15.2A as long as their Rule 8.9(b) reports include the information set forth above (even if their Rule 8.9(b) reports are submitted in a format different from that set forth in the attachment to this Regulatory Circular). The following table sets forth examples of which TPH has marking obligations under Rule 6.5(y) and reporting obligations under Rule 15.2A given different routing and execution circumstances. Note that may be simple or complex orders and may be part of, among other things, buy-write strategies, married put strategies, delta neutrdeal strategies, contingent strategies, and other stock-option

trading strategies with definitive option orders and stock orders. An order is tied to stock (and is, therefore, a Stock Order ) if, at the time the TPH representing the order on the Exchange receives or initiates the order, the TPH has knowledge that the order is coupled with an order(s) for the underlying stock or a security convertible to the underlying stock ( convertible security and, together with underlying stock, non-option ). The representing TPH must include an indicator on, subject to certain exceptions set forth in Rule 6.5(y). Important: The TPH must have knowledge of the non-option order for an order to meet the definition of a Stock Order. Scenario Marking Requirement 15.2A Requirement TPH 1 routes an option order to TPH 2 and TPH 2 TPH 1 discloses to TPH 2 intent to separately but concurrently route for execution a related stock order. TPH 2 executes the option order on CBOE, and TPH 1 executes the related stock order. TPH 1 routes an option order to TPH 2 but does not disclose to TPH 2 intent to separately but concurrently route for execution a related stock order. TPH 2 executes the option order on CBOE, and TPH 1 executes the stock order. None (TPH 2, the TPH that represents the option order to CBOE, has no knowledge of the related stock order) TPH 1 TPH 1 routes a stock-option order to TPH 2, who breaks up the order and routes the stock leg separately from the option leg. TPH 2 TPH 1 TPH 1 routes a stock-option order to TPH 2, who submits the stock-option order to CBOE for electronic execution. Non-TPH routes an option order to TPH 1 but does not disclose intent to separately but concurrently route for execution a related stock order. TPH 1 executes the option order on CBOE, and Non-TPH executes the stock order. Non-TPH routes a stock-option order to TPH 1, who submits the stock-option order to CBOE for electronic execution. None (tied to stock orders submitted to CBOE for electronic processing have no marking requirement) None (TPH 1, the TPH that represents the option order to CBOE, has no knowledge of the related stock order) None (tied to stock orders submitted to CBOE for electronic processing have no marking requirement) None (tied to stock orders submitted to CBOE for electronic processing have no reporting requirement) None (only TPHs have reporting obligation to CBOE) None (only TPHs have reporting obligation to CBOE) Please also note that the Stock Order type and reporting obligations are separate and distinct from the similarly named tied-hedge provision of Rule 6.74, Interpretation and Policy.10, which governs an execution strategy and which is subject to separate marking and record keeping requirements. Compliance Date: The implementation date for the marking and reporting obligations for is February 9, 2015. Firms that are required to submit these reports may do so via email to tiedtostock@cboe.com until a secure file transfer protocol is available. Page 2 of 9 Copyright 2014 CBOE. All rights reserved.

Additional Information: Please see rule filing SR-CBOE-2014-017 and Rules 6.5(y) and 15.2A for additional information regarding and the related marking and reporting requirements. Questions about CBOE rules or information required in the layout may be directed to the Regulatory Interpretations and Guidance team by telephone at (12) 786-8141 or by email at RegInterps@cboe.com. Attachment to RG14-171 Data Layout Requirements for Reports of Stock Transactions Related to (As of December 2014) I. File Requirements The requirements for the file format, file naming convention, and field formats will be as follows: Files transferred to the Exchanges should be comma delimited All files should be in the compressed GZIP format All files should be pushed to the designated location for retrieval Data provided by the firms that reside at the designated location will only be accessible to Regulatory staff Data examples included below are fictitious and do not reflect an actual firm or individual s information. A. File Naming Convention Along with standardizing the file formats, a standard naming convention will be used for identification from all TPHs when submitting the data. File names are to be supplied in lower case. Submissions are expected to be in a zipped CSV format. The naming convention is as follows: <tph_name>.<clear_firm>.<tts 1 >.YYYYMMDD.csv.gz tph_name -- >> TPH of data clear_firm -- >> Clear firm code data_file_type -- >> as defined in table above YYYYMMDD -- >> Year Month and Day file is sent 1 Stock Page of 9 Copyright 2014 CBOE. All rights reserved.

B. Field Legend Values that are not applicable/not required, are to be set to null and include the comma delimiter. The following table describes standard formats for the specified fields: Field Date Price Time Description YYYYMMDD format --- e.g., November 15, 2012 would be entered as --- >>>> 20121115 Maximum 20 characters including decimal point; up to 8 decimal places are allowed, although 4 decimal points are expected --- >>> e.g., 25045.2564 C. Valid Exchange Acronyms When an exchange acronym is to be entered, the following acronym format should be used: EXCH_ACR AMEX AMEX-O ARCA ARCA-O BATS BOX BSE BX BYX BZX C2 CBOE CBOT CFE CHX CME EDGA EDGX GEM ISE LIFFE MIA MIAX MSE NADTRF NASDQ NFX EXCH_NAME NYSE MKT NYSE AMEX Options Exchange NYSE ARCA Securities Exchange NYSE ARCA Options Exchange BATS OPTIONS EXCHANGE Boston Options exchange Boston Stock Exchange NASDAQ OMX BX BATS Y-Exchange BATS Z-Exchange C2 Options Exchange Chicago Board Options Exchange Chicago Board Of Trade (CME Group) CBOE Futures Exchange Chicago Stock Exchange CME Group EDGA Exchange EDGX Exchange ISE Gemini International Securities Exchange NYSE LIFFE MIAMI International Stock Exchange Miami Options Exchange Montreal Stock Exchange (TMX Group) NASDAQ TRF NASDAQ NASDAQ OMX Futures Exchange Page 4 of 9 Copyright 2014 CBOE. All rights reserved.

EXCH_ACR NSX NYMEX NYSE NYSETRF ONE OTC PHLX TSX OTHER EXCH_NAME National Stock Exchange NYMEX(CME Group) New York Stock Exchange NYSE TRF One Chicago Over-the-counter NASDAQ OMX PHLX Toronto Stock Exchange Other II. Trades Records Field File name: <tph_name>.<clear_firm>.tts.yyyymmdd.csv.gz Frequency: Daily File Descr: Information associated with the executed stock or commodity future contract (or options thereon) orders, a Clearing Trading Permit Holder or order service firm executed on behalf of market-maker pursuant to CBOE Rule 6.77. Fields identified as required must be completed if applicable (e.g., UNDERLYING_SYMBOL is identified as required, but is not applicable to commodity futures or options thereon). Values that are not applicable/not required are to be set to null and include the comma delimiter. The following layout includes the CMi field or FIX Tag where available. This information is provided for reference only. Data may be requested for trades executed on other exchanges. PRODUCT_TYPE Valid product types: E - Equity/Stock F - Future O - Option S - Strategy/Complex Order U - Option of Future Required for Time 21 Yes Timestamp 52 16:25:10:12 Character 1 Yes 167 O Page 5 of 9 Copyright 2014 CBOE. All rights reserved.

Required for Field Time 21 Yes Timestamp 52 16:25:10:12 BLKT - Block trade EXPH Exchange future for physical MAN - Manual Trade REG - Regular Trade CPSC - Cross product Cross 4 TRADE_TYPE Trade Character 5 Yes 277 REG CPSL - Cross Product Leg Trade CASH - Cash Trade INTSW - Intermarket Sweep LINK - Linkage Trade NXTDT - Next Day Trade TWDT - Two Day Trade 5 TRADE_ID Trade ID Unique identifier assigned to Numeric 20 Yes High; Trade this record of trade ID Low 17 25010561 6 ACCOUNT_CODE 7 ACCOUNT_ORIGIN 8 ORDER_ID 9 ORDER_ENTRY_DATE Account Code For Market Makers: Populate this field with the GROUP_ACRONYM of the Group Account if it is a joint account, or the TRADER_ACRONYM if trader account For CFE: Sub Account Refer to Appendix A for a list of Exchange origin codes, examples include: C - Public customer F - Clearing firm proprietary M - Exchange Market-Maker Unique identifier of the original order or quote associated with this trade. This field should match the ORDER_ID or QUOTE_ID field listed in the Order or Quote layouts as applicable (if requested) Original Order Entry Date; This field should match ORDER_ENTRY_DATE in the Orders layout, if requested Character 20 Yes Account 1 QEG Character 1 Yes Numeric 20 Yes Origin Type; Optional Data Order ID High Order ID Low 47 M Page 6 of 9 Copyright 2014 CBOE. All rights reserved. 11 25671441 1 Date 8 Yes Order Date 52 20121214

Field 10 UNDERLYING_SYMBOL 11 SYMBOL 12 EXPIRATION_DATE Underlying Security/Stock symbol of the product (not required for futures) Option/Futures contract symbol, e.g., For options - SPXW or SPY7 For futures - VX Legs class symbol for leg of a strategy Date on which the contract expires; Required for Time 21 Yes Timestamp 52 16:25:10:12 Character 10 Yes NEOP Character 10 Yes Product Key 55 NEOP Date 8 Yes 200; 205 2010119 1 EXERCISE_PRICE Exercise price Numeric 20 No 202 14 PUT_CALL_CODE Put/Call indicator: P - Put Character 1 No 201 P C Call 15 ORIG_ORDER_PRICE Price at which the original order was entered Numeric 20 Yes Price 44 5 16 ORIG_ORDER_QUANTITY Quantity for which the original Leaves Qty Numeric 20 Yes order was entered Traded Qty 8 50 17 TRADE_PRICE Price at which the trade executed Numeric 20 Yes Traded Price 1 2.5 18 TRADE_QUANTITY Quantity for this trade record Numeric 20 Yes Traded Qty 2 25 19 TRADER_ACRONYM Acronym or MPID of the trader User Character 5 Yes who entered the order Acronym 9825 RIB Identifier of the user 20 USER_ID associated with the order (e.g. Login); for CFE, Order Entry Character 10 Yes 50 TZCB Operator (OEO) 21 FIRM_ID Unique identifier of the executing firm Numeric 10 Yes 76 849 Clearing firm number of Executing firm used for this - for option 22 CLEAR_FIRM_CODE order: exchanges; Numeric Stock DTCC # 4 - for stock Yes 271 Options, Futures, Options on exchanges Futures OCC # 2 CLEAR_FIRM _ACRONYM Firm acronym of the clearing firm used by the executer of trade. Acronym should match its corresponding CLEAR_FIRM _NUMBER Character 5 Yes TQS Page 7 of 9 Copyright 2014 CBOE. All rights reserved.

Field 24 CMTA_CODE 25 OPEN_CLOSE_INDICATOR 26 USER_ROLE_CODE 27 CORRES_FIRM_CODE 28 BUY_SELL_INDICATOR 29 CREATE_REDEEM_TYPE 0 EXER_ASGN_TYPE 1 CRD_NUMBER 2 AGGREGATION_UNIT Give up firm of the buyer/seller as assigned by the OCC or NSCC Open Close Indicator of the buyer s position O Opening C Closing N the buy side is a quote or it is not feasible to identify Role of the trader that submitted the order P Principal A Agency Correspondent firm acronym. The firm may not be a member firm. The trader submitting an order to indicate the customer on whose behalf this order is submitted Indicates this trade as a buy or sell B Buy S Sell D Debit (for spreads) C Credit (for spreads; 0/Even default to Credit) H Sell Short (for stock) X Sell Short Exempt (for stock) Type identification for creation or redemption: C Create R Redeem E Exercise A Assigned For Central Registration Depository Number Aggregation unit identifier applicable to the beneficial account for reporting net long or net short positions Required for Time 21 Yes Timestamp 52 Character - for option exchanges; 4 - for stock exchanges Page 8 of 9 Copyright 2014 CBOE. All rights reserved. 16:25:10:12 Yes 49 67 Character 1 Yes 77 O Character 1 Yes 47 M Character 5 Yes 109 FES Character 1 Yes Character 1 No Side; Sell Short Indicator 54; 20101 Character 1 No A Character 8 Yes Character 20 No WEGP B

Field TRANS_DRCTN 4 TRANS_SITE 5 EXEC_VENUE Transaction direction identifies if this transaction is sent to or from. Valid values: TO FROM Transaction site identifies if this is transaction is sent to or from the customer or exchange Valid values: CUST EXCH Exchange venue of execution - Valid_Exchange_Acronyms Required for Time 21 Yes Timestamp 52 16:25:10:12 Character 4 No FROM Character 4 No CUST Character 10 Yes CBOE Trailer Record Field /Format 1 Record ID T = Trailer record ID Character 1 2 Process Date The processing date of the file. Numeric Record Count Number of records transmitted for the position date, excluding this trailer record Numeric 11 Page 9 of 9 Copyright 2014 CBOE. All rights reserved.