SEC invites comments on C2’s plans to adopt Complex Reserve Order functionality

Maria Nikolova

The change aims to add certain system functionality to C2’s System in order to provide a consistent technology offering for the Cboe Affiliated Exchanges.

The United States Securities and Exchange Commission (SEC) is inviting comments on plans by Cboe C2 Exchange, Inc., a part of Cboe Global Markets, Inc. (NASDAQ:CBOE), to adopt Complex Reserve Order functionality.

At present, C2 offers Reserve Order functionality for simple orders. Reserve Orders permit users to enter orders with both displayed and nondisplayed amounts. Reserve Orders provide Users with additional flexibility to manage and display their orders and additional control over their executions on C2.

Complex Reserve Orders would generally function in the same manner as simple Reserve Orders. Specifically, a Complex Reserve Order is a complex limit order with both a portion of the quantity displayed and a reserve portion of the quantity not displayed. Both the Display Quantity and Reserve Quantity of a Complex Reserve Order are available for execution.

When entering a Complex Reserve Order, a user must instruct C2 as to the quantity of the Complex Reserve Order to be initially displayed by the System (“Max Floor”). If the Display Quantity of a Complex Reserve Order is fully executed, the System will, in accordance with the user’s instruction, replenish the Display Quantity from the Reserve Quantity using one of the replenishment instructions. If the remainder of a Complex Reserve Order is less than the replenishment amount, the System will display the entire remainder of the Complex Reserve Order. The System creates a new timestamp for both the Display Quantity and Reserve Quantity of the Complex Reserve Order each time it is replenished from reserve.

The proposal aims to add certain system functionality to C2’s System in order to provide a consistent technology offering for the Cboe Affiliated Exchanges, as Cboe Options currently offers (and intends to offer following its migration to the same technology platform as C2) complex reserve order functionality. A consistent technology offering, in turn, will simplify the technology implementation, changes, and maintenance by C2 users that are also participants on Cboe Affiliated Exchanges.

The proposed rule change will provide users with additional flexibility to manage and display their orders and control their executions on the Exchange. This may encourage market participants to bring additional liquidity to the market, which benefits all investors.

Furthermore, this is set to provide users with greater harmonization between the order handling instructions available among the Cboe Affiliated Exchanges.

Interested persons are invited to submit comments via:

  • the SEC’s Internet comment form (; or
  • an e-mail to [email protected] Please include File Number SR-C2-2018-022 on the subject line.
  • 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-C2-2018-022.

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