PTG Comments on Cboe Disruptive Trading Rule Proposal
Feb 27, 2026
PTG encourages Cboe to withdraw the Proposal for immediate effectiveness and instead file the rule change with the Commission subject to public notice and comment. To the extent Cboe declines to withdraw the proposed rule change, PTG encourages the Securities and Exchange Commission (SEC) to abrogate it.
Codifying informal regulatory guidance or interpretations from regulatory circulars is not proper grounds for making content eligible for immediately effective rule filings. Regulatory circulars are subject to a much lower bar for issuance than rules and, importantly, are not subject to a notice and comment process designed to ensure new or amended rules are carefully vetted and understood by both the Commission and the industry participants who would be required to implement and comply with them. Regulatory circulars reflect only the self-regulatory organizations’ (“SRO”) views and must not replace the notice and comment process associated with formal rulemaking.