what's going on everyone i have another filing to talk about this one's out of sibo as well and
it's regarding block trade record keeping this is cfe 2021009 let's go and take a look so the
purpose of this one cfe rule 415 which is titled block trades governs block trades and cfe products
rule 415e currently requires that each cfe trading privilege holder or tph
that is a party to a blocked trade to record certain details regarding the transaction on
an order ticket those details include number one the contract including the expiration
number two the number of contracts traded number three the price of execution or premium
number four the time of execution number five the arrangement time if any number six the identity of
a counterparty number seven the transaction is a block trade number eight if applicable the account
number of the customer for which the block trade was executed and nine if applicable the expiration
strike price and type of option whether it's to put or call in the case of an option now purpose
continued the proposed rule change proposes to revise rule 415e to limit the application
of the block trade order ticket requirement to any tph that acts as an agent for a block trade
and to no longer apply that requirement to any tph that is a party to a block trade
in a principal capacity and not acting in the capacity as an agent the proposed rule change
also proposes to add a requirement to rule 415e that each tph involved in any blocked trade either
maintain records evidence and compliance with the criteria set forth in rule 415 or be able to
obtain those records from its customers involved in the block trade finally consistent with these
changes the proposed rule change proposes to revise a current cross reference in rule 415 e
to an order ticket in this context by referring to the order ticket as any required order ticket
instead of the current description of the order ticket referred to in the preceding sentence
purpose continued additionally the proposal change proposes to make clear
that any tph involved in a block trade must maintain records of the block trade
evidence in compliance with the criterion rule 415 or be able to obtain those records from its
customer involved in the block trade block trades and ecrp transactions are the two primary types
of off exchange transactions that are permitted under cfe rules given the similarities between
these two types of transactions block trades and ecrp transactions are subject to similar
record keeping and reporting requirements accordingly cfe believes that is appropriate
to align the order ticket requirement applicable to block trades under rule 415
with the corresponding order ticket requirement applicable to the ecrp under rule 414 and that
doing so will make it easier for tphs to comply with the exchange's record-keeping requirements
so we're trying to get some more compliance to the rules you hear that wilson or uh
morgan my guy no one's forcing the rules well they're trying to get him enforced
so that should be good news now specifically rule 415h requires that the notification to
the exchange of a blocked trade shall include number one whether the block trade is a single
leg transaction a transaction in a spread or a transaction in a strip number two the contract
identifier or product and contract expiration for a future or product expiration strike price and
type of option put or call in the same case of an option also price and quantity of the block trade
and whether the blocked rate is a buy or sell number three the time of execution number four
the arrangement time number five executing firm id or efid we have account clearing corporation
origin code customer type indicator code and any other information required by the
exchange additionally among other information that the exchange requires to be included as
part of the notification to the exchange of a block trade is the identity of the counterparty
now basically in essence the exchange believes that the proposed rule change is consistent with
section 6b of the act in general and furthers the objectives of section 6b16 and 6b57 in particular
in that it is designed number one to enable the exchange to enforce compliance by its
tphs and persons associated with its tphs with the provisions of the rules of the exchange number two
to prevent fraudulent and manipulative acts and practices to promote just and equitable
principles of trade to remove impediments to and perfect the mechanism of a free and open market
in a national market system and in general to protect investors and the public interest
so basically that's all i have for you this will be a proposal change so it's not going to
be implemented immediately or anything like that it's going to have to go through the process so
as far as implementation it could be 30 days from when this is published tomorrow have a good one