U.S. – CBOE Position Limits Aggregation

U.S. – CBOE Position Limits Aggregation

On 23 May 2019, CBOE Futures CFE issued position limits exemptions.

  • To amend CFE Rules 412 and 412A to permit TPHs to disaggregate positions, for
    CFE position limits/CFE position accountability level under certain circumstances.
  • Member TPHs is required to submit a request to Exchange and receive approval.

Position Limits Aggregation

  • Per exchange rules all positions in accounts where over 10% ownership must be
    aggregated with positions held and trading done unless exemption applies to TPH.
  • Unless CFTC Regulation 150.4(b) applicable to position, exchange has authorized.
  • If under common control, all positions must be aggregated, express or implied.

Seeking Exemption

  • If filing for exemption under CFE Rules 412(e)(iii) and/or 412A(f)(iii) or another
    under CFTC rules, must file in form, manner determined by exchange each time.
  • Must identify which, what facts warrant disaggregation, senior officer attestation
    that conditions met, any other information file by email, also if material change.


  • Will become effective May 24, 2019, or thereafter, as described in current notice.