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CBOE Proposes Rule Change Relating to Qualification Examinations

On September 20, the Securities and Exchange Commission approved a rule proposal filed by Cboe Exchange, Inc. (CBOE) related to the registration categories and qualification examinations required for Trading Permit Holders and associated persons that engage in trading activities on CBOE (Proposal).

In light of FINRA’s adoption of the Securities Industry Essentials Examination (SIE), which is a general knowledge examination that all new representative-level applicants will need to take as of October 1 (Implementation Date), CBOE proposed a rule change that would require new applicants seeking to register with CBOE in a representative capacity as of the Implementation Date to pass the SIE. To be eligible for such registration, an individual also must be associated with a firm, pass an appropriate qualification examination for a representative or principal, and satisfy certain other requirements. (For additional information regarding the SIE, please refer to the January 26, 2018 edition of Corporate & Financial Weekly Digest.)

In addition, CBOE proposed to adopt Interpretation and Policy .09 of Rule 3.6A and Interpretation and Policy .02 of Rule 9.3 to provide individuals acting as associated persons of firms who hold foreign registrations an alternative process to obtain a representative-level registration with CBOE. CBOE believes there is sufficient overlap between such foreign qualification requirements and the SIE to permit an exemption from the SIE requirement.

The new rule will go into effect on October 1, to coincide with the Implementation Date.

The Release is available here.

The Proposal is available here.

©2019 Katten Muchin Rosenman LLP


About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.


Stanley V. Polit, Katten Muchin, Financial Services lawyer, Corporate Regulatory Matters Attorney

Stanley Polit concentrates his practice in transactional, corporate and regulatory aspects of financial services matters. Stan is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, commodity trading advisers, financial institutions and general corporate clients.

Prior to joining Katten, Stan served as a council member for a national crisis management firm, where he specialized in crisis communication and merged media strategies. He has lectured extensively and conducted trainings related to these topics at numerous national and international conferences, including the National Communication Association's National Convention, the International Crisis and Risk Communication Conference and the Disaster Recovery Journal's World Business Continuity Conference.