Textbook
1. Introduction
2. Strategies
3. Customer accounts
4. Rules & regulations
4.1 Registration & reporting
4.2 The market
4.2.1 The Chicago Board Options Exchange
4.2.2 Dynamics
4.3 Options contracts
4.4 Taxation
4.5 Public communications
4.6 Other rules & regulations
5. Wrapping up
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4.2.1 The Chicago Board Options Exchange
Achievable Series 9
4. Rules & regulations
4.2. The market

The Chicago Board Options Exchange

The Chicago Board Options Exchange (CBOE) is the primary options exchange in the United States, although options contracts trade on many stock exchanges as well (including the New York Stock Exchange and American Stock Exchange). The CBOE is also a self-regulatory organization (SRO) that maintains regulatory power over the options market.

In this chapter, we’ll cover CBOE roles and its trading system.

Roles

There are three primary roles on the CBOE:

  • Designated Primary Market Makers (DPMs)
  • Market makers
  • Floor brokers

Designated Primary Market Makers (DPMs)

Similar to the Designated Market Maker (DMM) on the New York Stock Exchange (NYSE), the Designated Primary Market Maker (DPM) is responsible for maintaining a fair and orderly market. Depending on the market’s momentum, they can act in an agency or principal capacity. A continuous bid (buy) and ask (sell) spread must be established by the DPM, requiring the DPM to trade with the investing public at all times. The DPM is an employee of and compensated for their services by the CBOE.

Sidenote
Agency vs. principal capacity

Operating in an agency (broker) capacity means a financial professional connects their customer with another investor to complete a trade. If the transaction is executed, the professional is paid a commission.

Operating in a principal (dealer) capacity means a financial professional trades directly with their customer. If the customer wants to buy a security, the professional sells it out of their inventory at a marked-up price. If the customer wants to sell a security, the professional buys it into their inventory at a marked-down price.

Here’s a video breaking down a practice question on this topic:

Market makers

In addition to the DPM, there are dozens of private market makers that add additional liquidity to the options market. These organizations act solely in a principal capacity by buying options into or selling options from their inventory. To do so, they publish bid and ask quotes for at least one contract and accept orders from the DPM, other market makers, floor brokers (discussed below), and trading permit holders (usually broker-dealers; also discussed below). The more market makers that exist, the more trading partners there are in the options markets (and more liquidity).

Sidenote
Trading permit holders

A financial firm must obtain a permit to execute trades on the CBOE. After completing an application and paying a fee, firms (usually broker-dealers) are considered trading permit holders (TPHs). Only TPHs may submit trades to CBOE’s system for execution. To retain the permit, TPHs must pay monthly fees to the CBOE. Additionally, a TPH may not operate as a market maker or floor broker on the same business day*.

*CBOE Officials may permit a TPH to operate as a market maker or floor broker if a ‘fast’ market is declared. Fast markets are detailed in the next chapter.

Retail investors cannot place trades directly on options markets like the CBOE, as they typically gain access through trading permit holders.

TPHs must utilize CBOE Order Origin Codes when submitting trade requests. The following are the important codes to know for the exam that are used to identify the source of the transaction:

  • “B” - trade for broker-dealer’s account*
  • “C” - trade for broker-dealer customer’s account
  • “D” - trade for a non-TPH broker-dealer customer’s account
  • “F” - trade for OCC clearing member firm proprietary account
  • “M” - trade for CBOE TPH market maker orders
  • “N” - trade for non-CBOE market maker orders**
  • “W” - trade for broker-dealer professional*** customer’s account
  • “Y” - trade for Specialist**** responsible for trading the underlying stock on its primary exchange

*As a reminder, TPHs are typically broker-dealers.

**Origin code “N” is used for orders submitted by firms acting as market makers on options exchanges other than the CBOE.

***A “professional” customer typically places a significant number of trades on a daily basis.

****The “Specialist,” also known as the Designated Market Maker (DMM), is the primary entity responsible for maintaining a stock’s liquidity. The DMM trades directly with the public continuously to ensure investors can always find a trading partner.

Unlike the DPM, market makers are not employed by the CBOE and have no obligation to maintain a continuous market. However, the market maker must give prior written notice to the CBOE before withdrawing its quotes.

Floor brokers

Floor brokers also exist on the CBOE and work in a similar capacity to floor brokers on the NYSE. This role is typically filled by broker-dealer employees that execute large options trades for firm customers, although any person can act as a floor broker (as long as minimum CBOE standards are met). Floor brokers execute trades only in an agency capacity with the DPM, a market maker, or another floor broker.

The system

The CBOE’s market structure is considered a hybrid system. Known officially as the CBOE Hybrid System, it executes some trades electronically through computerized systems while allowing other trades to be handled manually by humans. Most marketable* and small trades are transmitted by trading permit holders to the exchange and are executed electronically, while larger and more complex trades get the human touch. CBOE rules generally require both the buyer and seller to report a trade to the exchange within 90 seconds of execution.

*A marketable trade can be executed quickly with little market movement. For example, a trade to buy an option for no more than a $4 premium when it was last quoted at a $3 premium is a marketable trade.

The electronic system responsible for executing most retail investor trades is the Retail Automatic Execution System (RAES). This system executes market and marketable limit orders for up to 50 contracts per trade at the best possible price, which could mean sending the transaction to the DPM or market maker (whichever has a better price). In plain terms, the “easy” trades are directed to and handled by RAES.

Definitions
Market order
An order to execute a securities trade at the next available price
Limit order
An order to execute a securities trade at a specified price or better

For example: an order to buy a call options contract at a $5 limit means the investor will only buy the contract if its premium is $5 or lower.

Limit orders “away” from the market* and complex orders are handled differently. Non-complex limit orders “away” from the market are typically diverted to the CBOE’s electronic book. When the order becomes marketable, the book dispatches the trade to the appropriate venue to be executed. Complex orders can be handled electronically through the CBOE’s Complex Order Book (COB) or sent to floor brokers to be executed manually.

Trading rotations

Trading rotations are performed at the opening and closing of the market every day. Typically conducted by the DPM (although a CBOE official may appoint a market maker for the job), a trading rotation analyzes market demand for options contracts to determine opening and closing premium prices. Only public market or limit orders are considered when a trading rotation is performed. While the CBOE’s standard trading hours are between 9:30am ET and 4:00pm ET, trade requests are submitted into the system by TPHs at all hours.

An opening rotation occurs before the market is open. The system collects bids and asks (trade requests) for call contracts with near-term expirations first, then works outward to longer-term expirations. After, the same process is completed with put contracts. After the rotation is complete, the contracts may be traded.

The CBOE utilizes two electronic systems while performing opening rotations. The Rapid Opening System (ROS) attempts to pair as many market and marketable limit orders as possible before market open. Let’s assume before the market opens that Investor A submits a market order for an opening purchase of a call, while Investor B submits a market order for an opening sale of the same call option. The ROS should pair these trades for execution at the price determined by the opening rotation. The ROS forwards unpairable orders, multi-leg orders*, and limit orders “away” from the market to DPMs and market makers once the market is open.

*Only single-leg trades are executed during the opening rotation. Multi-leg transactions (e.g., straddles, combinations, spreads) can only be executed during the normal trading session.

The Hybrid Opening System (HOSS) is the other electronic system utilized during opening rotations. HOSS accepts pre-market orders and distributes order data to market participants (DPMs, market makers, floor brokers). The distributed data also includes information related to unexecuted orders from the previous trading day. The DPMs and market makers use this data to determine their opening quotes for the day. Once those quotes are determined, HOSS computes the opening (premium) prices for outstanding options contracts.

A closing rotation is similar to an opening rotation, but is performed at the close of the market.

Sidenote
Trading halts

A trading halt occurs when the stock market is shut down temporarily, typically because of market volatility. If a trading halt is implemented, the options markets are also shut down. This should make sense - how can an investor determine the value of an option if the underlying security or index is not trading?

Sometimes referred to as trading curbs, circuit breakers shut the market down for short periods when there’s a significant and fast market decline. The S&P 500 represents “the market” for circuit breaker purposes. Here are the rules, which are enforced daily:

7% decline before 3:25pm ET

  • 15-minute trading halt

13% decline before 3:25pm ET

  • 15-minute trading halt

20% decline at any time

  • Market shuts down for the day

Circuit breakers don’t completely fix the problem, but it stops the downward momentum temporarily. Virtually all stock exchanges enforce the rule today. Circuit breakers don’t commonly occur, but they were enforced during the 2010 Flash Crash (when the market fell by 9% in just minutes) and four separate times during the COVID-19 market volatility in March 2020.

Investors may continue to submit options trade and exercise requests during a halt, but no executions may occur until the market is re-opened. Once the stock markets are re-opened, the options markets go through the same opening rotation process as was performed at the market open.

Key points

Chicago Board Options Exchange (CBOE)

  • Primary options trading exchange
  • SRO with regulatory abilities in the options markets

Designated Primary Market Maker (DPM)

  • Facilitates options trading on CBOE
  • Helps create a fair and orderly market
  • Must maintain continuous quote
  • May operate in an agency or principal capacity
  • Similar to DMM on NYSE

Market makers

  • Trades contracts with other participants
  • Provide additional liquidity to the options markets
  • Operates in a principal capacity only
  • May withdraw quotes if written notice is provided to exchange

Floor broker

  • Trades contracts with other participants
  • Operate in an agency capacity only
  • Typically represent broker-dealers on exchange floor

Trading permit holder (TPH)

  • Financial firms with access to CBOE’s trading venue

CBOE’s hybrid system

  • Part automated electronic system that executes orders
  • Part manual system allowing human intervention

Retail Automatic Execution System (RAES)

  • Primary retail trade execution system
  • Executes market and marketable limit orders
  • Handles up to 50 contracts per trade

CBOE’s electronic book

  • Handles non-complex limit orders “away” from the market

CBOE’s complex order book

  • Handles complex orders received by the system

Opening rotation

  • Determines opening premium prices based on market data
  • Performed at market open and after trading halts
  • Two electronic systems:
    • Rapid opening system (ROS)
    • Hybrid opening system (HOSS)

Closing rotation

  • Determines closing premium prices based on market data
  • Performed at market close

Circuit breakers (trading halts)

  • Shuts market down during fast and large market (S&P 500) declines
  • Thresholds:
    • 7% decline - 15-minute halt
    • 13% decline - 15-minute halt
    • 20% decline - rest of day halt

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