Notice2025-15321

Self-Regulatory Organizations; Cboe Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Amend Its Rules Regarding the Position and Exercise Limits for Options on the iShares Bitcoin Trust ETF, Grayscale Bitcoin Trust ETF, Grayscale Bitcoin Mini Trust BTC, and the Bitwise Bitcoin ETF

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
August 13, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 90 Issue 154 (Wednesday, August 13, 2025)</title>
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[Federal Register Volume 90, Number 154 (Wednesday, August 13, 2025)]
[Notices]
[Pages 39008-39015]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-15321]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-103663; File No. SR-CBOE-2025-056]


Self-Regulatory Organizations; Cboe Exchange, Inc.; Notice of 
Filing and Immediate Effectiveness of a Proposed Rule Change To Amend 
Its Rules Regarding the Position and Exercise Limits for Options on the 
iShares Bitcoin Trust ETF, Grayscale Bitcoin Trust ETF, Grayscale 
Bitcoin Mini Trust BTC, and the Bitwise Bitcoin ETF

August 8, 2025.

    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that 
on August 6, 2024, Cboe Exchange, Inc. (the ``Exchange'' or ``Cboe 
Options'') filed with the Securities and Exchange Commission 
(``Commission'') a proposed rule change as described in Items I and II 
below, which Items have been prepared by the Exchange. The Commission 
is publishing this notice to

[[Page 39009]]

solicit comments on the proposed rule change from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change

    Cboe Exchange, Inc. (the ``Exchange'' or ``Cboe Options'') proposes 
to amend its Rules regarding the position and exercise limits for 
options on iShares Bitcoin Trust ETF (``IBIT''), Grayscale Bitcoin 
Trust ETF (``GBTC''), Grayscale Bitcoin Mini Trust BTC (``BTC''), and 
the Bitwise Bitcoin ETF (``BITB'') (collectively, the ``Bitcoin 
ETFs''). The text of the proposed rule change is provided in Exhibit 5.
    The text of the proposed rule change is also available on the 
Exchange's website (<a href="http://www.cboe.com/AboutCBOE/CBOELegalRegulatoryHome.aspx">http://www.cboe.com/AboutCBOE/CBOELegalRegulatoryHome.aspx</a>), and at the Exchange's Office of the 
Secretary.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the Exchange included statements 
concerning the purpose of and basis for the proposed rule change and 
discussed any comments it received on the proposed rule change. The 
text of these statements may be examined at the places specified in 
Item IV below. The Exchange has prepared summaries, set forth in 
sections A, B, and C below, of the most significant aspects of such 
statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

1. Purpose
    The Exchange proposes to amend its Rules regarding the position and 
exercise limits for options on the Bitcoin ETFs. Specifically, the 
proposed rule change amends Rule 8.30, Interpretation and Policy .10 to 
delete the 25,000 contract position limit for each Bitcoin ETF option. 
As a result, the position limit for each Bitcoin ETF option would be 
determined in accordance with Rule 8.30, Interpretation and Policy .07 
and be based on trading in each Bitcoin ETF during the most-recent six-
month period.\3\
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    \3\ Pursuant to Rule 8.42, Interpretation and Policy .02, the 
exercise limits for options on the Bitcoin ETFs are equivalent to 
the position limits prescribed for such options in current Rule 
8.30, Interpretation and Policy .10. Therefore, currently, the 
exercise limit for each Bitcoin ETF option is 25,000 contracts. The 
proposed rule change would modify the exercise limit for each 
Bitcoin ETF option to be equivalent to the position limit prescribed 
in Rule 8.30, Interpretation and Policy .07 (which may be 25,000, 
50,000, 75,000, 200,000, or 250,000, depending on the six-month 
trading volume or the six-month trading volume and outstanding 
shares of the Bitcoin ETF).
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    Each Bitcoin ETF is an exchange-traded fund (``ETF'') that holds 
Bitcoin and is listed on a national equities exchange.\4\ On November 
22, 2024, the Securities and Exchange Commission (the ``Commission'') 
noticed the Exchange's filing and immediate effectiveness of a proposed 
rule change to list and trade IBIT, GBTC, BTC, and BITB options.\5\ The 
position and exercise limits for each Bitcoin ETF option are 25,000 
contracts, the lowest limit available in equity options.\6\
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    \4\ Nasdaq received approval to list and trade Bitcoin-Based 
Commodity-Based Trust Shares in IBIT pursuant to Rule 5711(d) of 
Nasdaq. See Securities Exchange Act Release No. 99306 (January 10, 
2024), 89 FR 3008 (January 17, 2024) (SR-NASDAQ-2023-016) (Order 
Granting Accelerated Approval of Proposed Rule Changes, as Modified 
by Amendments Thereto, To List and Trade Bitcoin-Based Commodity-
Based Trust Shares and Trust Units). IBIT started trading on January 
11, 2024. NYSE Arca received approval to list and trade Bitcoin-
Based Commodity-Based Trust Shares in GBTC, BTC, and BITB pursuant 
to NYSE Arca Rule 8.201-E(c)(1). See Securities Exchange Act Release 
Nos. 99306 (January 10, 2024), 89 FR 3008 (January 17, 2024) (Order 
Granting Accelerated Approval of Proposed Rule Changes, as Modified 
by Amendments Thereto, to list and trade options on, among other 
ETFs, GBTC) (SR-NYSEARCA-2021-90); 100610 (July 26, 2024) (order 
approving listing and trading of Commodity-Based Trust Shares of 
BTC, among other ETFs), 89 FR 62821 (August 1, 2024) (SR-NYSEARCA-
2023-45); and 99306 (January 10, 2024), 89 FR 3008 (January 17, 
2024) (order approving listing and trading of Commodity-Based Trust 
Shares of BITB, among other ETFs) (SR-NYSEARCA-2021-90).
    \5\ See Securities Exchange Act Release No. 101711 (November 22, 
2024), 89 FR 94846 (November 29, 2024) (SR-CBOE-2024-051) (``Bitcoin 
ETF Options Notice'').
    \6\ See Rules 8.30, Interpretation and Policy .10 and 8.42, 
Interpretation and Policy .02.
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    Per the Commission ``rules regarding position and exercise limits 
are intended to prevent the establishment of options positions that can 
be used or might create incentives to manipulate or disrupt the 
underlying market so as to benefit the options positions.'' \7\ For 
this reason, the Commission requires that ``position and exercise 
limits must be sufficient to prevent investors from disrupting the 
market for the underlying security by acquiring and exercising a number 
of options contracts disproportionate to the deliverable supply and 
average trading volume of the underlying security.'' \8\ Based on its 
review of the data and analysis provided by the Exchange, the 
Commission concluded that the 25,000 contract position limit for non-
FLEX Bitcoin ETF options satisfied these objectives.\9\
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    \7\ See Securities Exchange Act Release No. 101128 (September 
20, 2024), 89 FR 78942, 78946 (September 26, 2024) (SR-ISE-2024-03) 
(Notice of Filing of Amendment Nos. 4 and 5 and Order Granting 
Accelerated Approval of a Proposed Rule Change, as Modified by 
Amendment Nos. 1, 4, and 5, To Permit the Listing and Trading of 
Options on the iShares Bitcoin Trust) (``IBIT Options Approval 
Order'').
    \8\ Id.
    \9\ Id.; Securities Exchange Act Release Nos. 101386 (October 
18, 2024), 89 FR 84960 (October 24, 2024) (SR-NYSEAMER-2024-49) (the 
``GBTC, BTC, and BITB Options Approval Order'').
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    While the Exchange proposed a 25,000 contract position limit for 
each Bitcoin option in its rule filings to list and trade these 
options, the Exchange nonetheless believed that evidence existed to 
support a much higher position limit. Specifically, when initially 
approving Bitcoin ETF options trading, the Commission considered and 
reviewed data and analysis of Nasdaq ISE, LLC (``ISE'') (with respect 
to IBIT options) and NYSE American, LLC (``NYSE American'') (with 
respect to GBTC, BTC, and BITB options) when initially approving for 
listing the Bitcoin ETF options that the exercisable risk associated 
with a position limit of 25,000 contracts represented only 0.4% of the 
outstanding shares of IBIT; \10\ 0.9% of the outstanding shares of 
GBTC; 0.7% of the outstanding shares of BTC; and 3.6% of the 
outstanding shares of BITB.\11\ The Commission also considered and 
reviewed ISE's and NYSE American's statements, as applicable, that with 
a position limit of 25,000 contracts on the same side of the market for 
each Bitcoin ETF option: (1) with 611,040,000 shares of IBIT 
outstanding, 244 market participants would have to simultaneously 
exercise their positions to place IBIT under stress; \12\ (2) with 
284,570,100 shares of GBTC outstanding, 114 market participants would 
have to simultaneously exercise their positions to place GBTC under 
stress; (3) with 366,950,100 shares of BTC outstanding, 147 market 
participants would have to simultaneously exercise their positions to 
place BTC under stress; and (4) with 68,690,000 shares of BITB 
outstanding, 27 market participants would have to simultaneously 
exercise their positions to place BITB under stress.\13\ Based on the 
Commission's review of this information and analysis, the Commission 
concluded that the 25,000-contract position and exercise limit for each 
of IBIT, GBTC, BTC, and BITB options were designed to prevent

[[Page 39010]]

investors from disrupting the market for the underlying security by 
acquiring and exercising a number of options contracts disproportionate 
to the deliverable supply and average trading volume of the underlying 
security, and to prevent the establishment of options positions that 
can be used or might create incentives to manipulate or disrupt the 
underlying market so as to benefit the options position.\14\
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    \10\ See IBIT Options Approval Order, at 78946 (data as of 
August 12, 2024).
    \11\ See GBTC, BTC, and BITB Options Approval Order, at 84970 
(data as of August 30, 2024).
    \12\ See IBIT Options Approval Order, at 78946 (data as of 
August 12, 2024).
    \13\ See GBTC, BTC, and BITB Options Approval Order, at 84971 
(data as of August 30, 2024).
    \14\ See IBIT Options Approval Order, at 78946; and GBTC, BTC, 
and BITB Options Approval Order, at 84971.
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    Each Bitcoin ETF option would currently qualify for the 250,000 
contract position (and exercise) limit pursuant to the criteria in Rule 
8.30, Interpretation and Policy .02, which requires that, for the most 
recent six-month period, trading volume for the underlying security be 
at least 100 million shares.\15\ As of November 25, 2024, the market 
capitalization and average daily volume (``ADV'') for the preceding 
three months \16\ for each Bitcoin ETF was:
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    \15\ Rule 8.30, Interpretation and Policy .02(e) provides that 
to be eligible for the 250,000 contract limit, either the most 
recent six-month trading volume of the underlying security must have 
totaled at least 100,000,000 shares or the most recent six-month 
trading volume of the underlying security must have totaled at least 
75,000,000 shares and the underlying security must have at least 
300,000,000 shares currently outstanding.
    \16\ The market capitalization for each Bitcoin ETF was 
determined by multiplying a settlement price (IBIT--$54.02, $75.42--
GBTC, $42.16--BTC, $51.70--BITB) by the number of shares outstanding 
(IBIT--866,040,000, GBTC--273,950,100, BTC--82,939,964, BITB--
79,950,100). IBIT data was acquired from <a href="https://www.ishares.com/us/products/333011/ishares-bitcoin-trust-etf">https://www.ishares.com/us/products/333011/ishares-bitcoin-trust-etf</a>, and GBTC, BTC, and BITB 
data acquired from FactSet.

----------------------------------------------------------------------------------------------------------------
                                                                                               Three-month ADV
                           Bitcoin ETF                              Market capitalization         (shares)
----------------------------------------------------------------------------------------------------------------
IBIT.............................................................          $46,783,480,800            39,421,877
GBTC.............................................................           20,661,316,542             3,829,597
BTC..............................................................            3,496,748,882             2,036,369
BITB.............................................................            4,095,157,000             2,480,478
----------------------------------------------------------------------------------------------------------------

    Therefore, each Bitcoin ETF is well-above the requisite 100,000,000 
shares necessary to qualify for the 250,000,000 contract position and 
exercise limit. Also, as of November 25, 2024, there were 19,787,762 
Bitcoins in circulation.\17\ At a price of $94,830,\18\ that equates to 
a market capitalization of greater than $1.876 trillion. If a position 
limit of 250,000 contracts were considered, the exercisable risk would 
represent 2.89%,\19\ 9.13%,\20\ 30.14%,\21\ and 31.27%\22\ of IBIT, 
GBTC, BTC, and BITB shares outstanding, respectively. Given each 
Bitcoin ETF's liquidity, the current 25,000 contract position and 
exercise limit for each Bitcoin ETF option is extremely conservative.
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    \17\ See <a href="https://www.coingecko.com/en/coins/bitcoin">https://www.coingecko.com/en/coins/bitcoin</a>.
    \18\ This is the approximate price of Bitcoin from 4:00pm ET on 
November 25, 2024.
    \19\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/866,040,000 shares 
outstanding).
    \20\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/273,950.100 shares 
outstanding).
    \21\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/82,939,964 BTC shares 
outstanding).
    \22\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/79,950,100 BITB shares 
outstanding).
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    Position and exercise limits are designed to limit the number of 
options contracts traded on the exchange in an underlying security that 
an investor, acting alone or in concert with others directly or 
indirectly, may control. These limits, which are described in Rules 
8.30 and 8.42, are intended to address potential manipulative schemes 
and adverse market impacts surrounding the use of options, such as 
disrupting the market in the security underlying the options. Position 
and exercise limits must balance concerns regarding mitigating 
potential manipulation and the cost of inhibiting potential hedging 
activity that could be used for legitimate economic purposes.
    To achieve this balance, the Exchange proposes to remove each 
Bitcoin ETF from the table of position limits in Rule 8.30, 
Interpretation and Policy .10 to permit options on each Bitcoin ETF to 
trade similar to all other ETF options for which the Exchange does not 
have other Rules that increase the position (and exercise) limits of 
ETF options to levels outside of the limits set forth in Rules 8.30, 
Interpretations and Policies .02 and 8.42. As a result of removing the 
Bitcoin ETFs from the table in Rule 8.30, Interpretation and Policy 
.10, the position and exercise limits for each Bitcoin ETF option from 
25,000 to 250,000 contracts based on the parameters in Rule 8.30, 
Interpretation and Policy .02. By removing the Bitcoin ETFs from the 
table in Rule 8.30, Interpretation and Policy .10, each Bitcoin ETF 
would be subject to subsequent six-month reviews to determine future 
position and exercise limits similar to all other options subject to 
Rules 8.30, Interpretation and Policy .02 and 8.42.
    With respect to IBIT options, in its filing proposing to amend the 
position and exercise limits of IBIT options,\23\ ISE considered IBIT's 
market capitalization and ADV measured against those of other 
underlying securities, as well as the position limit of 250,000 
contracts in relation to the position limits of other options. In 
measuring IBIT against other securities, ISE aggregated market 
capitalization and volume data for securities that have defined 
position limits utilizing data from The Options Clearing Corporations 
(``OCC'').\24\ This pool of data took into consideration 3,897 options 
on single stock securities, excluding broad based ETFs.\25\ Next, ISE 
aggregated the data based on market capitalization and ADV and grouped 
option symbols by position limit utilizing statistical thresholds for 
ADV, based on 90 days, and market capitalization that were one standard 
deviation above the mean for each position limit category (i.e., 
25,000, 50,000 to 65,000, 75,000, 100,000 to less than 250,000, and 
250,000.\26\ Rule 8.30 sets out position limits for various contracts. 
For example, on the Exchange, like ISE, a 25,000 contract position 
limit applies to options with an underlying security that does not meet 
the requirements for a higher options contract position limit. ISE 
performed an exercise to demonstrate the IBIT options position limit 
relative to other

[[Page 39011]]

options symbols in terms of market capitalization and ADV. For 
reference, the market capitalization for IBIT was $46,783,480,800 \27\ 
with an ADV, for the preceding three months prior to November 25, 2024, 
of 39,421,877 shares. By comparison, if IBIT were compared to the 1,934 
stocks underlying options that have position limits of 250,000 
contracts (and less than 500,000 contracts), IBIT would rank in the 
88th percentile for market capitalization and the 99th percentile for 
ADV.
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    \23\ See Securities Exchange Act Release No. 102682 (March 14, 
2025), 90 FR 13233, 13235-13237 (March 20, 2025) (SR-ISE-2024-62).
    \24\ The computations are based on OCC data from November 25, 
2024. Data displaying zero values in market capitalization or ADV 
were removed.
    \25\ IBIT has one asset and therefore is not comparable to a 
broad-based ETF where there are typically multiple components.
    \26\ Rule 8.30, Interpretation and policy .02 sets out position 
limits for various contracts. For example, at 25,000 contract limit 
applies to those options having an underlying security that does not 
meet the requirements for a higher options contract limit. The 
Exchange notes that position limits may also be higher due to 
corporate actions in the underlying equities, such as a stock split. 
See <a href="https://www.theocc.com/market-data/market-data-reports/series-and-trading-data/position-limits">https://www.theocc.com/market-data/market-data-reports/series-and-trading-data/position-limits</a>. As a result, ISE's pool of data 
considered higher position limits than 250,000 contracts, where 
applicable.
    \27\ The market capitalization was determined by multiplying a 
settlement price of ($54.02) by the number of shares outstanding 
(866,040,000). This figure was acquired as of November 25, 2024. See 
<a href="https://www.ishares.com/us/products/333011/ishares-bitcoin-trust-etf">https://www.ishares.com/us/products/333011/ishares-bitcoin-trust-etf</a>.
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    ISE also analyzed a position limit of 250,000 contracts for IBIT by 
regressing the market capitalization figures and 90-day ADV of all non-
ETF equities, against their respective position limit figures. From 
this regression, ISE indicated it determined the implied coefficients 
to create a formulaic method for determining an appropriate position 
limit. In this case, the modeled position limit was 565,796 
contracts.\28\ Based on this analysis, the Exchange believes the 
proposed rule change that would result in a 250,000 contract position 
and exercise limit for IBIT is appropriate.
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    \28\ ISE stated it utilized this formula to arrive at the number 
of contracts: ((46,783,380,800 mkt cap * 0.0000002630 market cap 
coefficient) + (39,421,877 ADV * 0.0140402219 ADV coefficient)).
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    Second, ISE reviewed IBIT's data relative to the market 
capitalization of the entire Bitcoin market in terms of exercise risk 
and availability of deliverables. Utilizing data as of November 25, 
2024, there were 19,787,762 Bitcoins in circulation.\29\ ISE took a 
price of $94,830,\30\ which equates to a market capitalization of 
greater than $1.876 trillion. If a position limit of 250,000 contracts 
were considered, the exercisable risk would represent only 2.89% \31\ 
of the outstanding shares of IBIT. Since IBIT has a creation and 
redemption process managed through the issuer, the position limit 
sought to the total market capitalization of the entire Bitcoin market. 
In this case, the exercisable risk for options on IBIT would be less 
than 0.072% of the market capitalization of all outstanding 
Bitcoin.\32\ Assuming a scenario where all options on IBIT shares were 
exercised given a 250,000 contract per same side position (and 
exercise) limit, this would have a virtually unnoticed impact on the 
entire Bitcoin market. This ISE analysis demonstrates that a position 
(and exercise) limit of 250,000 same side contracts for IBIT is 
appropriate for IBIT options given its liquidity.
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    \29\ See <a href="https://www.coingecko.com/en/coins/bitcoin">https://www.coingecko.com/en/coins/bitcoin</a>.
    \30\ This is the approximate price of Bitcoin from 4:00pm ET on 
November 25, 2024.
    \31\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/866,040,000 shares 
outstanding).
    \32\ This number was arrived at with this calculation: ((250,000 
limit * 100 shares per option * $54.02 settle)/(19,787,762 Bitcoin 
outstanding * $94,830 Bitcoin price)).
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    Third, ISE reviewed a position (and exercise) limit of 250,000 
contracts for IBIT options by comparing it to position limits for 
derivative products regulated by the Commodity Futures Trading 
Commission (``CFTC''). While the CFTC, through the relevant Designated 
Contract Markets, only regulates options positions based upon delta 
equivalents (creating a less stringent standard), ISE examined 
equivalent Bitcoin futures position limits. In particular, ISE looked 
at the CME Bitcoin futures contract that has a position limit of 2,000 
futures.\33\ On October 22, 2024, CME Bitcoin futures settled at 
$94,945.\34\ On October 22, 2024, IBIT settled at $54.02, which would 
equate to greater than 17,557,898 shares of IBIT if the CME notional 
position limit was utilized. Since substantial portions of any 
distributed options portfolio is likely to be out of the money on 
expiration, an options position limit equivalent to the CME position 
limit for bitcoin futures (considering that all options deltas are 
<=1.00) should be a bit higher than the CME implied 175,578 limit. Of 
note, unlike options contracts, CME position limits are calculated on a 
net futures equivalent basis by contract and include contracts that 
aggregate into one or more base contracts according to an aggregation 
ratio(s).\35\ Therefore, if a portfolio includes positions in options 
on futures, CME would aggregate those positions into the underlying 
futures contracts in accordance with a table published by CME on a 
delta equivalent value for the relevant spot month, subsequent spot 
month, single month and all month position limits.\36\ If a position 
exceeds position limits because of an option assignment, CME permits 
market participants to liquidate the excess position within one 
business day without being considered in violation of its rules. 
Additionally, if at the close of trading, a position that includes 
options exceeds position limits for futures contracts, when evaluated 
using the delta factors as of that day's close of trading, but does not 
exceed the limits when evaluated using the previous day's delta 
factors, then the position shall not constitute a position limit 
violation. Based on the aforementioned ISE analysis, the Exchange 
believes that the proposed 250,000 contracts for position and exercise 
limits is appropriate.
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    \33\ See CME Rulebook Chapter 350 (description of CME Bitcoin 
Futures) and Chapter 5, Position Limit, Position Accountability and 
Reportable Level Table in the Interpretations & Special Notices. 
Each CME Bitcoin futures contract is valued at five Bitcoins as 
defined by the CME CF Bitcoin Reference Rate (``BRR''). See CME Rule 
35001.
    \34\ 2,000 futures at a 5 Bitcoin multiplier (per the contract 
specifications) equates to $949,450,000 (2000 contracts * 5 Bitcoin 
per contract * $94,945 price of November Bitcoin future) of notional 
value.
    \35\ See <a href="https://www.cmegroup.com/education/courses/market-regulation/position-limits/position-limits-aggregation-of-contracts-and-table.htm">https://www.cmegroup.com/education/courses/market-regulation/position-limits/position-limits-aggregation-of-contracts-and-table.htm</a>.
    \36\ Id.
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    Fourth, ISE analyzed a position and exercise limit of 250,000 for 
IBIT options against other options on ETFs with an underling commodity, 
namely SPDR Gold Shares (``GLD''), iShares Silver Trust (``SLV''), and 
ProShares Bitcoin ETF (``BITO'').\37\ GLD has a float of 306.1 million 
shares \38\ and a position limit of 250,000 contract. SLV has a float 
of 520.7 million shares \39\ and a position limit of 250,000 contract. 
Finally, BITO has 107.65 million shares outstanding \40\ and a position 
limit of 250,000 contract. As previously noted, position and exercise 
limits are designed to limit the number of options contracts traded on 
the exchange in an underlying security that an investor, acting alone 
or in concert with others directly or indirectly, may control. A 
position limit exercise in GLD would represent 8.17% of the float of 
GLD; a position limit exercise in SLV would represent 4.8% of the float 
of SLV, and a position limit exercise of BITO would represent 23.22% of 
the float of BITO. In comparison, a 250,000 contract position limit in 
IBIT would represent 2.89% of the float of IBIT. Consequently, a 
250,000 position and exercise limit is more conservative than the 
standard applied to GLD, SLV and BITO, and thus appropriate.
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    \37\ GLD, SLV and BITO each hold one asset in trust similar to 
IBIT.
    \38\ See <a href="https://www.ssga.com/us/en/intermediary/etfs/spdr-gold-shares-gld">https://www.ssga.com/us/en/intermediary/etfs/spdr-gold-shares-gld</a>.
    \39\ See <a href="https://www.ishares.com/us/products/239855/ishares-silver-trust-fund">https://www.ishares.com/us/products/239855/ishares-silver-trust-fund</a>.
    \40\ See <a href="https://www.marketwatch.com/investing/fund/bito">https://www.marketwatch.com/investing/fund/bito</a>.
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    Fifth, ISE noted that IBIT options began trading in penny 
increments as of January 2, 2025 pursuant to the Penny Interval 
Program.\41\ The Commission

[[Page 39012]]

noted that evidence contained in both the Exchanges' Report and the 
Cornerstone analysis demonstrates that the Penny Pilot has benefitted 
investors and other market participants in the form of narrower 
spreads.\42\ The most actively traded options classes are included in 
the Penny Program based on certain objective criteria (trading volume 
thresholds and initial price tests). As noted in the Penny Approval 
Order, the Penny Program reflects a certain level of trading interest 
(either because the class is newly listed or a class that experience a 
significant growth in investor interest) to quote in finer trading 
increments, which in turn should benefit market participants by 
reducing the cost of trading such options.\43\ IBIT options are among a 
select group of products that have achieved a certain level of 
liquidity that have garnered it the ability to trade in finer 
increments. Failing to increase position and exercise limits for IBIT 
options, now that it is trading in finer increments, may artificially 
inhibit liquidity and create price inefficiency.
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    \41\ The Exchange may add to the Penny Program a newly listed 
option class provided that (i) it is among the 300 most actively 
traded multiply listed option classes, as ranked by National Cleared 
Volume at OCC, in its first full calendar month of trading and (ii) 
the underlying security is priced below $200 or the underlying index 
is at an index level below $200. Any option class added under this 
provision will be added on the first trading day of the month after 
it qualifies and will remain in the Penny Program for one full 
calendar year, after which it will be subject to the Annual Review 
described in Rule 5.4(d). The Exchange may add any option class to 
the Penny Program, provided that (i) it is among the 75 most 
actively traded multiply listed option classes, as ranked by 
National Cleared Volume at OCC, in the past six full calendar months 
of trading and (ii) the underlying security is priced below $200 or 
the underlying index is at an index level below $200. Any option 
class added under this provision will be added on the first trading 
day of the second full month after it qualifies and will remain in 
the Penny Program for the rest of the calendar year, after which it 
will be subject to the Annual Review as described in Rule 5.4(d). 
See Rule 5.4(d).
    \42\ See Securities Exchange Act Release No. 88532 (April 1, 
2020), 67 FR 19545, 19548 (April 7, 2020) (File No. 4-443) (Joint 
Industry Plan; Order Approving Amendment No. 5 to the Plan for the 
Purpose of Developing and Implementing Procedures Designed To 
Facilitate the Listing and Trading of Standardized Options To Adopt 
a Penny Interval Program) (``Penny Approval Order'').
    \43\ Id. at 19548.
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    With respect to GBTC, BTC, and BITB, the Exchange reviewed data 
presented by NYSE Arca, Inc. (``NYSE Arca'') in its filings to amend 
the position and exercise limits for GBTC, BTC, and BITB options.\44\ 
First, the Exchange reviewed NYSE Arca's comparison of the market 
capitalization of each of these three Bitcoin ETFs relative to the 
market capitalization of the entire Bitcoin market in terms of exercise 
risk and availability of deliverables. As noted above, as of November 
25, 2024, there were 19,787,762 Bitcoins in circulation.\45\ At a price 
of $94,830 per Bitcoin,\46\ that equates to a market capitalization of 
greater than $1.876 trillion. If a position (and exercise) limit of 
250,000 contracts were considered, the exercisable risk would represent 
9.13%,\47\ 30.14%,\48\ and 31.27% \49\ of GBTC, BTC, and BITB shares 
outstanding, respectively. Since each of GBTC, BTC, and BITB has a 
creation and redemption process managed through the issuer (whereby 
Bitcoin is used to create shares of each such Bitcoin ETF), the 
position and exercise limit can be compared to the total market 
capitalization of the entire Bitcoin market, and in that case, the 
exercisable risk for options on GBTC, BTC, and BITB would represent 
less than 0.10%,\50\ 0.06%,\51\ and 0.07%,\52\ respectively, of all 
Bitcoin outstanding. The Exchange notes that if each of GBTC, BTC, and 
BITB options were subject to a 250,000-contract position and exercise 
limit (based on each ETF's trading volume), and if all options on GBTC, 
BTC, or BITB shares were exercised at once, this occurrence would have 
a virtually unnoticed impact on the entire Bitcoin market. This NYSE 
Arca analysis demonstrates that a 250,000-contract position (and 
exercise) limit for each of GBTC, BTC, and BITB options would be 
appropriate given each of these Bitcoin ETF's liquidity.
---------------------------------------------------------------------------

    \44\ See Securities Exchange Act Release Nos. 102402 (February 
11, 2025), 90 FR 9765, 9767 (SR-NYSEArca-2025-07) (notice of filing 
regarding position and exercise limits for GBTC options); and 102441 
(February 18, 2025), 90 FR 10518, 10520--10521 (notice of filing 
regarding position and exercise limits for BTC and BITB options).
    \45\ See <a href="https://www.coingecko.com/en/coins/bitcoin">https://www.coingecko.com/en/coins/bitcoin</a>.
    \46\ This is the approximate price of Bitcoin from 4:00pm ET on 
November 25, 2024.
    \47\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/273,950,100 shares 
outstanding).
    \48\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/82,939,964 shares 
outstanding).
    \49\ This percentage is arrived at with this equation: (250,000 
contract limit * 100 shares per option/79,950,100 BITB shares 
outstanding).
    \50\ This number was arrived at with this calculation: ((250,000 
limit * 100 shares per option * $75.42 settle)/(19,787,762 Bitcoin 
outstanding * $94,830 Bitcoin price)).
    \51\ This number was arrived at with this calculation: ((250,000 
limit * 100 shares per option * $42.16 settle)/(19,787,762 Bitcoin 
outstanding * $94,830 Bitcoin price)).
    \52\ This number was arrived at with this calculation: ((250,000 
limit * 100 shares per option * $51.70 settle)/(19,787,762 Bitcoin 
outstanding * $94,830 Bitcoin price)).
---------------------------------------------------------------------------

    As ISE did with respect to IBIT options, NYSE Arca compared a 
position and exercise limit of 250,000 contracts to the position limit 
of CME Bitcoin futures, which as noted above, have a position limit of 
2,000 futures. On October 22, 2024, CME Bitcoin futures settled at 
$94,945. On October 22, 2024, GBTC settled at $53.64, BTC settled at 
$29.90, and BITB settled at $36.74, which would equate to greater than 
17,700,410 shares of GBTC, 31,754,180 shares of BTC, and 25,842,406 
shares of BITB, if the CME notional position limit was utilized.\53\ 
Since substantial portions of any distributed options portfolio re 
likely to be out of the money at expiration, an options position limit 
equivalent to the CME position limit for Bitcoin futures (considering 
that all options deltas are <=1.00) should be a bit higher than the CME 
implied 175,578 limit.
---------------------------------------------------------------------------

    \53\ 2,000 futures at a 5-Bitcoin multiplier (per the contract 
specifications) equates to $949,450,000 (2000 contracts * 5 Bitcoin 
per contract * $94,945 price of November Bitcoin future) of notional 
value.
---------------------------------------------------------------------------

    The Exchange notes, unlike options contracts, CME position limits 
are calculated on a net futures-equivalent basis by contract and 
include contracts that aggregate into one or more base contracts 
according to an aggregation ratio(s).\54\ Therefore, if a portfolio 
includes positions in options on futures, CME would aggregate those 
positions into the underlying futures contracts in accordance with a 
table published by CME on a delta equivalent value for the relevant 
spot month, subsequent spot month, single month and all month position 
limits.\55\ If a position exceeds position limits because of an option 
assignment, CME permits market participants to liquidate the excess 
position within one business day without being considered in violation 
of its rules. Additionally, if at the close of trading, a position that 
includes options exceeds position limits for futures contracts, when 
evaluated using the delta factors as of that day's close of trading but 
does not exceed the limits when evaluated using the previous day's 
delta factors, then the position shall not constitute a position limit 
violation. Considering CME's position limits on futures for Bitcoin, 
the Exchange believes that the proposed position and exercise limits 
for GBTC, BTC, and BITB options are appropriate.
---------------------------------------------------------------------------

    \54\ See CME Rulebook Chapter 5, Position Limit, Position 
Accountability and Reportable Level Table in the Interpretations & 
Special Notices.
    \55\ Id.
---------------------------------------------------------------------------

    Finally, as ISE did, NYSE Arca also compared a position and 
exercise limit of 250,000 contracts for GBTC, BTC, and BITB against the 
position and exercise limits for GLD and SLV options. GLD has a float 
of 306.1 million shares \56\ and a position and exercise limit of 
250,000 contract. SLV has a float of 520.7 million shares \57\ and a 
position and

[[Page 39013]]

exercise limit of 250,000 contracts. As previously noted, position and 
exercise limits are designed to limit the number of options contracts 
traded on the exchange in an underlying security that an investor, 
acting alone or in concert with others directly or indirectly, may 
control. A position limit exercise in GLD would represent 8.17% of the 
float of GLD; and a position limit exercise in SLV would represent 4.8% 
of the float of SLV. In comparison, a 250,000-contract position limit 
would represent 9.13% of the GBTC float, 30.14% of the BTC float, and 
31.27% of the BITB float. A 250,000 contract position and exercise 
limit for each of GBTC, BTC, and BITB is comparable with the standard 
applied to GLD and SLV and is therefore appropriate.
---------------------------------------------------------------------------

    \56\ See <a href="https://www.ssga.com/us/en/intermediary/etfs/spdr-gold-shares-gld">https://www.ssga.com/us/en/intermediary/etfs/spdr-gold-shares-gld</a>.
    \57\ See <a href="https://www.ishares.com/us/products/239855/ishares-silver-trust-fund">https://www.ishares.com/us/products/239855/ishares-silver-trust-fund</a>.
---------------------------------------------------------------------------

    The Exchange believes the above information demonstrates that each 
Bitcoin ETF option has more than sufficient liquidity to garner an 
increased position and exercise limit of 250,000 contracts. The 
Exchange believes that any concerns related to manipulation and 
protection of investors are mollified by the significant liquidity 
provision in each Bitcoin ETF. The Exchange states that, as a general 
principle, increases in active trading volume and deep liquidity of the 
underlying securities do not lead to manipulation and/or disruption.
    The Exchange believes the proposed rule change would lead to a more 
liquid and competitive market environment for the Bitcoin ETF options, 
which will benefit customers that trade these options. Further, the 
reporting requirement for such options would remain unchanged. Thus, 
the Exchange will still require that each TPH organization that 
maintains positions in impacted options on the same side of the market, 
for its own account or for the account of a customer, report certain 
information to the Exchange. This information includes, but would not 
be limited to, the options' positions, whether such positions are 
hedged and, if so, a description of the hedge(s). Market-Makers would 
continue to be exempt from this reporting requirement, however, the 
Exchange may access Market-Maker position information.\58\ Moreover, 
the Exchange's requirement that TPH organizations file reports with the 
Exchange for any customer who held aggregate large long or short 
positions on the same side of the market of 200 or more option 
contracts of any single class for the previous day will remain at this 
level and will continue to serve as an important part of the Exchange's 
surveillance efforts.\59\
---------------------------------------------------------------------------

    \58\ OCC through the Large Option Position Reporting (``LOPR'') 
system acts as a centralized service provider for Trading Permit 
Holder (``TPH'') compliance with position reporting requirements by 
collecting data from each TPH or TPH organization, consolidating the 
information, and ultimately providing detailed listings of each TPHs 
report to the Exchange, as well as Financial Industry Regulatory 
Authority, Inc. (``FINRA''), acting as its agent pursuant to a 
regulatory services agreement (``RSA'').
    \59\ See Rule 8.43(a).
---------------------------------------------------------------------------

    The Exchange also has no reason to believe that the growth in 
trading volume in Bitcoin ETF options will not continue. Rather, the 
Exchange expects continued options volume growth in the Bitcoin ETFs as 
opportunities for investors to participate in the options markets 
increase and evolve. The Exchange believes that the current position 
and exercise limits applicable to the Bitcoin ETF options are 
restrictive and may hamper the listed options markets from being able 
to compete fairly and effectively with the over-the-counter (``OTC'') 
markets. OTC transactions occur through bilateral agreements, the terms 
of which are not publicly disclosed to the marketplace. As such, OTC 
transactions do not contribute to the price discovery process on a 
public exchange or other lit markets. The Exchange believes that 
without the proposed changes to position and exercise limits for 
Bitcoin ETF options, market participants will find the 25,000 contract 
position and exercise limit an impediment to their business and 
investment objectives as well as an impediment to efficient pricing. As 
such, market participants may find the less transparent OTC markets a 
more attractive alternative to achieve their investment and hedging 
objectives, leading to a retreat from the listed options markets, where 
trades are subject to reporting requirements and daily surveillance. 
However, the Exchange notes each Bitcoin ETF option's position (and 
exercise) limits would be reviewed on a six-month basis, pursuant to 
Rule 8.30, Interpretation and Policy .02, similar to other options.
    Today, the Exchange has an adequate surveillance program in place 
for options.\60\ Additionally, the Exchange is a member of the 
Intermarket Surveillance Group (``ISG'') under the Intermarket 
Surveillance Group Agreement. ISG members work together to coordinate 
surveillance and investigative information sharing in the stock, 
options, and futures markets. Further, Cboe has an RSA with FINRA for 
certain market surveillance, investigation and examinations functions. 
Pursuant to a multi-party 17d-2 joint plan, all options exchanges 
allocate amongst themselves and FINRA responsibilities to conduct 
certain options-related market surveillance that are common to rules of 
all options exchanges.\61\ The Exchange also has reviews in place to 
identify continued compliance with the Exchange's listing standards.
---------------------------------------------------------------------------

    \60\ The surveillance program includes surveillance patterns for 
price and volume movements as well as patterns for potential 
manipulation (e.g., spoofing and marking the close).
    \61\ Section 19(g)(1) of the Act, among other things, requires 
every self-regulatory organization (``SRO'') registered as a 
national securities exchange or national securities association to 
comply with the Act, the rules and regulations thereunder, and the 
SRO's own rules, and, absent reasonable justification or excuse, 
enforce compliance by its members and persons associated with its 
members. See 15 U.S.C. 78q(d)(1) and 17 CFR 240.17d-2. Section 
17(d)(1) of the Act allows the Commission to relieve an SRO of 
certain responsibilities with respect to members of the SRO who are 
also members of another SRO (``common members''). Specifically, 
Section 17(d)(1) allows the Commission to relieve an SRO of its 
responsibilities to: (i) receive regulatory reports from such 
members; (ii) examine such members for compliance with the Act and 
the rules and regulations thereunder, and the rules of the SRO; or 
(iii) carry out other specified regulatory responsibilities with 
respect to such members.
---------------------------------------------------------------------------

2. Statutory Basis
    The Exchange believes the proposed rule change is consistent with 
the Securities Exchange Act of 1934 (the ``Act'') and the rules and 
regulations thereunder applicable to the Exchange and, in particular, 
the requirements of Section 6(b) of the Act.\62\ Specifically, the 
Exchange believes the proposed rule change is consistent with the 
Section 6(b)(5) \63\ requirements that the rules of an exchange be 
designed to prevent fraudulent and manipulative acts and practices, to 
promote just and equitable principles of trade, to foster cooperation 
and coordination with persons engaged in regulating, clearing, 
settling, processing information with respect to, and facilitating 
transactions in securities, to remove impediments to and perfect the 
mechanism of a free and open market and a national market system, and, 
in general, to protect investors and the public interest. Additionally, 
the Exchange believes the proposed rule change is consistent with the 
Section 6(b)(5) \64\ requirement that the rules of an exchange not be 
designed to permit unfair discrimination between customers, issuers, 
brokers, or dealers.
---------------------------------------------------------------------------

    \62\ 15 U.S.C. 78f(b).
    \63\ 15 U.S.C. 78f(b)(5).
    \64\ Id.
---------------------------------------------------------------------------

    In particular, the Exchange believes the proposed rule change will 
remove impediments to and perfect the mechanism of free and open market 
and a national market system, and, in general, protect investors and 
the public

[[Page 39014]]

interest, because it will provide market participants with the ability 
to more effectively execute their trading and hedging activities. Also, 
based on current trading volume, the resulting increase in the position 
(and exercise) limits for each Bitcoin ETF option may allow Market-
Makers to maintain their liquidity in these options in amounts 
commensurate with the continued high consumer demand in each Bitcoin 
ETF option. Subjecting the Bitcoin ETF options to the position limits 
in Rule 8.30, Interpretation and Policy .02 and corresponding exercise 
limits in Rule 8.42 may also encourage other liquidity providers to 
continue to trade on the Exchange rather than shift their volume to OTC 
markets, which will enhance the process of price discovery conducted on 
the Exchange through increased order flow. The Exchange notes the 
proposed rule change would further allow institutional investors to 
utilize Bitcoin ETF options for prudent risk management purposes.
    In support of the proposed rule change, the Exchange cites the in-
depth analysis of each of ISE and NYSE Arca did in their respective 
filings, as noted above, each of ISE and NYSE Arca considered, among 
other things: (1) applicable Bitcoin ETF's market capitalization and 
ADV, and a 250,000 contract position and exercise limit in relation to 
the position limits of options on other securities; (2) market 
capitalization of the entire Bitcoin market in terms of exercise risk 
and availability of deliverables; and (3) comparing a 250,000 contract 
position limit to position limits for derivative products regulated by 
the CFTC. Based on the Exchange's review of these analyses, the 
Exchange believes that subjecting the Bitcoin ETF options to the 
position (and exercise) limits set forth in Rule 8.30, Interpretation 
and Policy .02 (which may go up to 250,000 contracts) is more than 
appropriate. The proposed position and exercise limits reasonably and 
appropriately balance the liquidity provisioning in the market against 
the prevention of manipulation. The Exchange believes these proposed 
limits are effectively designed to prevent an individual customer or 
entity from establishing options positions that could be used to 
manipulate the market of the underlying as well as the Bitcoin 
market.\65\
---------------------------------------------------------------------------

    \65\ See Securities Exchange Act Release No. 39489 (December 24, 
1997), 63 FR 276 (January 5, 1998) (SR-CBOE-1997-11).
---------------------------------------------------------------------------

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will 
impose any burden on competition that is not necessary or appropriate 
in furtherance of the purposes of the Act. The Exchange does not 
believe the proposed rule change will impose any burden on intramarket 
competition that is not necessary or appropriate in furtherance of the 
purposes of the Act because all TPHs would be subject to the same 
position and exercise limit for each Bitcoin ETF option, as set by 
Rules 8.30, Interpretation and Policy .02 and 8.42. The Exchange does 
not believe the proposed rule change will impose any burden on 
intermarket competition, and may benefit competition, as the proposed 
rule change is identical proposed rule changes of other options 
exchanges recently approved by the Commission.\66\ The Exchange 
believes that the proposed rule change may provide additional 
opportunities for market participants to continue to efficiently 
achieve their investment and trading objectives for the Bitcoin ETF 
options.
---------------------------------------------------------------------------

    \66\ See Securities Exchange Act Release Nos. 103564 (July 29, 
2025) (SR-ISE-2024-62) (order approving ISE proposed rule change to 
amend position and exercise limits for IBIT options); 103567 (July 
29, 2025) (SR-NYSEARCA-2025-07) (order approving NYSE Arca proposed 
rule change to amend position and exercise limits for GBTC options); 
and 103568 (July 29, 2025) (SR-NYSEARCA-2025-10) (order approving 
NYSE Arca proposed rule change to amend position and exercise limits 
for BTC and BITB options).
---------------------------------------------------------------------------

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    The Exchange neither solicited nor received written comments on the 
proposed rule change.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    The Exchange has filed the proposed rule change pursuant to Section 
19(b)(3)(A)(iii) of the Act \67\ and Rule 19b-4(f)(6) thereunder.\68\ 
Because the foregoing proposed rule change does not: (i) significantly 
affect the protection of investors or the public interest; (ii) impose 
any significant burden on competition; and (iii) become operative for 
30 days from the date on which it was filed, or such shorter time as 
the Commission may designate, it has become effective pursuant to 
Section 19(b)(3)(A)(iii) of the Act \69\ and subparagraph (f)(6) of 
Rule 19b-4 thereunder.\70\
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    \67\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \68\ 17 CFR 240.19b-4(f)(6).
    \69\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \70\ 17 CFR 240.19b-4(f)(6). In addition, Rule 19b-4(f)(6) 
requires a self-regulatory organization to give the Commission 
written notice of its intent to file the proposed rule change at 
least five business days prior to the date of filing of the proposed 
rule change, or such shorter time as designated by the Commission. 
The Exchange has satisfied the pre-filing requirement.
---------------------------------------------------------------------------

    A proposed rule change filed under Rule 19b-4(f)(6) \71\ under the 
Act does not normally become operative prior to 30 days after the date 
of the filing. However, pursuant to Rule 19b-4(f)(6)(iii),\72\ the 
Commission may designate a shorter time if such action is consistent 
with the protection of investors and the public interest. The Exchange 
has requested that the Commission waive the 30-day operative delay so 
that the proposal may become operative immediately upon filing. The 
Commission previously approved the removal of the 25,000 contract 
position and exercise limit for IBIT, BTC, GBTC, and BITB, such that 
those funds will be subject to the position and exercise limits as 
determined for equity options for which no set limit has been otherwise 
established on that exchange.\73\ The Exchange is proposing similarly 
to remove of the 25,000 contract position and exercise limit for IBIT, 
BTC, GBTC, and BITB, such that those funds will be subject to the 
position and exercise limits as determined by the position limit rules 
at Rule 8.30, Interpretation and Policy .10. The Exchange has provided 
information regarding IBIT, BTC, GBTC, and BITB, including, among other 
things, information regarding trading volume, and the market 
capitalization of IBIT, BTC, GBTC, and BITB and surveillance procedures 
that will apply. The Commission notes that the proposal raises no new 
or novel legal issues and would simply provide an additional venue for 
trading IBIT, BTC, GBTC, and BITB with position and exercise limits 
that may be higher than 25,000 contracts. Therefore, the Commission 
believes that waiver of the 30-day operative delay is consistent with 
the protection of investors and the public interest. Accordingly, the 
Commission hereby waives the 30-day operative delay and designates the 
proposed rule change as operative upon filing.\74\
---------------------------------------------------------------------------

    \71\ 17 CFR 240.19b-4(f)(6).
    \72\ 17 CFR 240.19b-4(f)(6)(iii).
    \73\ See supra note 66.
    \74\ For purposes only of waiving the 30-day operative delay, 
the Commission has also considered the proposed rule's impact on 
efficiency, competition, and capital formation. See 15 U.S.C. 
78c(f).
---------------------------------------------------------------------------

    At any time within 60 days of the filing of the proposed rule 
change, the

[[Page 39015]]

Commission summarily may temporarily suspend such rule change if it 
appears to the Commission that such action is necessary or appropriate 
in the public interest, for the protection of investors, or otherwise 
in furtherance of the purposes of the Act. If the Commission takes such 
action, the Commission shall institute proceedings to determine whether 
the proposed rule should be approved or disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views, and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#1c6e697079317f7371717972686f5c6f797f327b736a"><span class="__cf_email__" data-cfemail="5624233a337b35393b3b333822251625333578313920">[email&#160;protected]</span></a>. Please include 
file number
    SR-CBOE-2025-056 on the subject line.

Paper Comment

    <bullet> Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR- CBOE-2025-056. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the filing will be available for inspection and 
copying at the principal office of the Exchange. Do not include 
personal identifiable information in submissions; you should submit 
only information that you wish to make available publicly. We may 
redact in part or withhold entirely from publication submitted material 
that is obscene or subject to copyright protection. All submissions 
should refer to file number SR-CBOE-2025-056 and should be submitted on 
or before September 3, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\75\
---------------------------------------------------------------------------

    \75\ 17 CFR 200.30-3(a)(12), (59).
---------------------------------------------------------------------------

J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2025-15321 Filed 8-12-25; 8:45 am]
BILLING CODE 8011-01-P


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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.