704 Federal Register / Vol. 90, No. 3 / Monday, January 6, 2025 / Notices 

5Copies of the submission, all subsequent 

amendments, all written statements with respect to 

the proposed rule change that are filed with the 

Commission, and all written communications 

relating to the proposed rule change between the 

Commission and any person, other than those that 

may be withheld from the public in accordance 

with the provisions of 5 U.S.C. 552, will be 

available for website viewing and printing in the 

Commission’s Public Reference Room, 100 F Street 

NE, Washington, DC 20549, on official business 

days between the hours of 10 a.m. and 3 p.m. 

Copies of the filing also will be available for 

inspection and copying at the principal office of 

SRO. 

6 17 CFR 200.30–3(a)(12). 

1 15 U.S.C. 78s(b)(1). 

2 17 CFR 240.19b–4. 

3Nasdaq received approval to list and trade 

Bitcoin-Based Commodity-Based Trust Shares in 

IBIT pursuant to Rule 5711(d) of Nasdaq. See 

Securities Exchange Act Release No. 99306 (January 

10, 2024), 89 FR 3008 (January 17, 2024) (SR– 

NASDAQ–2023–016) (Order Granting Accelerated 

Approval of Proposed Rule Changes, as Modified by 

Amendments Thereto, To List and Trade BitcoinBased Commodity-Based Trust Shares and Trust 

Units). IBIT started trading on January 11, 2024. 

4See Securities Exchange Act Release No. 101128 

(September 20, 2024), 89 FR 78942 (September 26, 

2024) (SR–ISE–2024–03) (Notice of Filing of 

Amendment Nos. 4 and 5 and Order Granting 

Accelerated Approval of a Proposed Rule Change, 

as Modified by Amendment Nos. 1, 4, and 5, To 

Permit the Listing and Trading of Options on the 

iShares Bitcoin Trust) (‘‘IBIT Approval Order’’). ISE 

began trading IBIT options on November 19, 2024. 

5Options on Fidelity Wise Origin Bitcoin Fund, 

ARK 21Shares Bitcoin ETF, Grayscale Bitcoin Trust 

(BTC), Grayscale Bitcoin Mini Trust BTC, and 

Bitwise Bitcoin ETF are also subject to a 25,000 

contract position and exercise limit. 

6See supra note 4, IBIT Approval Order, 89 FR 

78946. 

7See id. 

8See id. 

rule change, is available on the 

Exchange’s website at http://

www.cboe.com/AboutCBOE/CBOELegal

RegulatoryHome.aspx, at the principal 

office of the Exchange, and on the 

Commission’s website at https://

www.sec.gov/rules-regulations/selfregulatory-organization-rulemaking/ 

national-securities-exchanges?file_

number=SR-CboeBZX-2024-130. 

II. Solicitation of Comments 

Interested persons are invited to 

submit written data, views, and 

arguments concerning the foregoing, 

including whether the proposed rule 

change is consistent with the Act.5

Comments may be submitted 

electronically by using the 

Commission’s internet comment form 

(https://www.sec.gov/rules-regulations/ 

self-regulatory-organizationrulemaking/national-securitiesexchanges?file_number=SR-CboeBZX2024-130) or by sending an email to 

rule-comments@sec.gov. Please include 

file number SR–CboeBZX–2024–130 on 

the subject line. Alternatively, paper 

comments may be sent to Secretary, 

Securities and Exchange Commission, 

100 F Street NE, Washington, DC 

20549–1090. All submissions should 

refer to file number SR–CboeBZX–2024– 

130. To help the Commission process 

and review your comments more 

efficiently, please use only one method. 

The Commission will post all comments 

on the Commission’s internet website 

(https://www.sec.gov/rules-regulations/ 

self-regulatory-organizationrulemaking/national-securitiesexchanges?file_number=SR-CboeBZX2024-130). Do not include personal 

identifiable information in submissions; 

you should submit only information 

that you wish to make available 

publicly. We may redact in part or 

withhold entirely from publication 

submitted material that is obscene or 

subject to copyright protection. All 

submissions should refer to file number 

SR–CboeBZX–2024–130 and should be 

submitted on or before January 27, 2025. 

For the Commission, by the Division of 

Trading and Markets, pursuant to delegated 

authority.6

Stephanie J. Fouse, 

Assistant Secretary. 

[FR Doc. 2024–31773 Filed 1–3–25; 8:45 am] 

BILLING CODE 8011–01–P 

SECURITIES AND EXCHANGE 

COMMISSION 

[Release No. 34–102065; File No. SR–ISE– 

2024–62] 

Self-Regulatory Organizations; Nasdaq 

ISE, LLC; Notice of Filing of Proposed 

Rule Change To Increase the Position 

and Exercise Limits for iShares Bitcoin 

Trust ETF 

December 31, 2024. 

Pursuant to Section 19(b)(1) of the 

Securities Exchange Act of 1934 

(‘‘Act’’),1 and Rule 19b–4 thereunder,2

notice is hereby given that on December 

20, 2024, Nasdaq ISE, LLC (‘‘ISE’’ or 

‘‘Exchange’’) filed with the Securities 

and Exchange Commission 

(‘‘Commission’’) the proposed rule 

change as described in Items I and II 

below, which Items have been prepared 

by ISE. The Commission is publishing 

this notice to solicit comments on the 

proposed rule change from interested 

persons. 

I. Self-Regulatory Organization’s 

Statement of the Terms of Substance of 

the Proposed Rule Change 

The Exchange proposes to amend 

Options 9, Sections 13 and 15 to 

propose an increase to the position and 

exercise limits for iShares Bitcoin Trust 

ETF (‘‘IBIT’’). 

The text of the proposed rule change 

is available on the Exchange’s website at 

https://listingcenter.nasdaq.com/ 

rulebook/ise/rules, at the principal 

office of the Exchange, and at the 

Commission’s Public Reference Room. 

II. Self-Regulatory Organization’s 

Statement of the Purpose of, and 

Statutory Basis for, the Proposed Rule 

Change 

In its filing with the Commission, the 

Exchange included statements 

concerning the purpose of and basis for 

the proposed rule change and discussed 

any comments it received on the 

proposed rule change. The text of these 

statements may be examined at the 

places specified in Item IV below. The 

Exchange has prepared summaries, set 

forth in sections A, B, and C below, of 

the most significant aspects of such 

statements. 

A. Self-Regulatory Organization’s 

Statement of the Purpose of, and 

Statutory Basis for, the Proposed Rule 

Change 

1. Purpose 

The Exchange proposes to amend 

Options 9, Section 13, Position Limits, 

and Options 9, Section 15, Exercise 

Limits, to increase the position and 

exercise limits for options on IBIT from 

25,000 to 250,000 contracts. 

IBIT is an Exchange-Traded Fund 

(‘‘ETF’’) that holds bitcoin and is listed 

on The Nasdaq Stock Market LLC.3 On 

September 20, 2024, ISE received 

approval to list options on IBIT.4 The 

position and exercise limits for IBIT 

options are 25,000 contracts as stated in 

Options 9, Sections 13 and 15, the 

lowest limit available in options.5

Per the Commission ‘‘rules regarding 

position and exercise limits are 

intended to prevent the establishment of 

options positions that can be used or 

might create incentives to manipulate or 

disrupt the underlying market so as to 

benefit the options positions.’’ 6 For this 

reason, the Commission requires that 

‘‘position and exercise limits must be 

sufficient to prevent investors from 

disrupting the market for the underlying 

security by acquiring and exercising a 

number of options contracts 

disproportionate to the deliverable 

supply and average trading volume of 

the underlying security.’’ 7 Based on its 

review of the data and analysis provided 

by the Exchange, the Commission 

concluded that the 25,000 contract 

position limit for non-FLEX IBIT 

options satisfied these objectives.8


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9See id. Data represents figures from August 12, 

2024. 10See id. Data represents figures from August 12, 

2024. 11See id. 12Options 9, Section 13(g), Equity Option 

Position Limits, provides at subparagraph (i) that 

the position limit shall be 250,000 contracts for 

options: (a) on an underlying stock or ExchangeTraded Fund Share which had trading volume of 

at least 100,000,000 shares during the most recent 

six-month trading period; or (b) on an underlying 

stock or Exchange-Traded Fund Share which had 

trading volume of at least 75,000,000 shares during 

the most recent six-month trading period and has 

at least 300,000,000 shares currently outstanding. 

13The market capitalization was determined by 

multiplying a settlement price of ($54.02) by the 

number of shares outstanding (866,040,000). This 

figure was acquired as of November 25, 2024. See 

https://www.ishares.com/us/products/333011/ 

ishares-bitcoin-trust-etf. 

14See https://www.coingecko.com/en/coins/ 

bitcoin. 

15This is the approximate price of bitcoin from 

4:00pm ET on November 25, 2024. 

16This percentage is arrived at with this equation: 

(250,000 contract limit * 100 shares per option/ 

866,040,000 shares outstanding). 

17The computations are based on OCC data from 

November 25, 2024. Data displaying zero values in 

market capitalization or ADV were removed. 

18 IBIT has one asset and therefore is not 

comparable to a broad based ETF where there are 

typically multiple components. 

19 ISE Options 9, Section 13(d) sets out position 

limits for various contracts. For example, a 25,000 

contract limit applies to those options having an 

underlying security that does not meet the 

requirements for a higher options contract limit. 

The Exchange notes that position limits may also 

be higher due to corporate actions in the underlying 

equities, such as a stock split. See https:// 

www.theocc.com/market-data/market-data-reports/ 

series-and-trading-data/position-limits. As a result, 

the Exchange’s pool of data considered higher 

position limits than 250,000 contracts, where 

applicable. 

20The market capitalization was determined by 

multiplying a settlement price of ($54.02) by the 

number of shares outstanding (866,040,000). This 

figure was acquired as of November 25, 2024. See 

https://www.ishares.com/us/products/333011/ 

ishares-bitcoin-trust-etf. 

While the Exchange proposed an 

aggregated 25,000 contract position 

limit for IBIT options in its IBIT 

Approval Order, it nonetheless believed 

that evidence existed to support a much 

higher position limit. Specifically, the 

Commission has considered and 

reviewed the Exchange’s analysis in its 

IBIT Approval Order that the 

exercisable risk associated with a 

position limit of 25,000 contracts 

represented only 0.4% of the 

outstanding shares of IBIT.9 The 

Commission also has considered and 

reviewed the Exchange’s statement its 

IBIT Approval Order that with a 

position limit of 25,000 contracts on the 

same side of the market and 611,040,00 

shares of IBIT outstanding, 244 market 

participants would have to 

simultaneously exercise their positions 

to place IBIT under stress.10 Based on 

the Commission’s review of this 

information and analysis, the 

Commission concluded that the 

proposed position and exercise limits of 

25,000 contracts were designed to 

prevent investors from disrupting the 

market for the underlying security by 

acquiring and exercising a number of 

options contracts disproportionate to 

the deliverable supply and average 

trading volume of the underlying 

security, and to prevent the 

establishment of options positions that 

can be used or might create incentives 

to manipulate or disrupt the underlying 

market so as to benefit the options 

position.11

IBIT currently qualifies for a 250,000 

contract position limit pursuant to the 

criteria in Options 9, Section 13(g), 

which requires that, for the most recent 

six-month period, trading volume for 

the underlying security be at least 

100,000,000 shares.12 As of November 

25, 2024, the market capitalization for 

IBIT was $46,783,480,800 13 with an 

average daily volume (‘‘ADV’’), for the 

preceding three months prior to 

November 25, 2024, of 39,421,877 

shares. IBIT is well above the requisite 

minimum of 100,000,000 shares 

necessary to qualify for the 250,000 

contract position limit. Also, as of 

November 25, 2024, there are 

19,787,762 bitcoins in circulation.14 At 

a price of $94,830,15 that equates to a 

market capitalization of greater than 

$1.876 trillion US. If a position limit of 

250,000 contracts were considered, the 

exercisable risk would represent 

2.89%16 of the outstanding shares 

outstanding of IBIT. Given IBIT’s 

liquidity, the current 25,000 position 

limit is extremely conservative. 

Position limits, and exercise limits, 

are designed to limit the number of 

options contracts traded on the 

exchange in an underlying security that 

an investor, acting alone or in concert 

with others directly or indirectly, may 

control. These limits, which are 

described in ISE Options 9, Sections 13 

and 15, are intended to address 

potential manipulative schemes and 

adverse market impacts surrounding the 

use of options, such as disrupting the 

market in the security underlying the 

options. Position and exercise limits 

must balance concerns regarding 

mitigating potential manipulation and 

the cost of inhibiting potential hedging 

activity that could be used for legitimate 

economic purposes. To achieve this 

balance, ISE proposes to increase IBIT’s 

position and exercise limits from 25,000 

to 250,000 contracts. ISE believes that 

250,000 contracts is the appropriate 

position and exercise limit based on its 

analysis described below. 

First, ISE considered IBIT’s market 

capitalization and Average Daily 

Volume (‘‘ADV’’), and prospective 

position limit in relation to other 

securities. In measuring IBIT against 

other securities, ISE aggregated market 

capitalization and volume data for 

securities that have defined position 

limits utilizing data from The Options 

Clearing Corporations (‘‘OCC’’).17 This 

pool of data took into consideration 

3,897 options on single stock securities, 

excluding broad based ETFs.18 Next, the 

data was aggregated based on market 

capitalization and ADV and grouped by 

option symbol and position limit 

utilizing statistical thresholds for ADV, 

based on ninety days, and market 

capitalization that were one standard 

deviation above the mean for each 

position limit category (i.e., 25,000, 

50,000 to 65,000, 75,000, 100,000 to less 

than 250,000, and 250,000).19 This 

exercise was performed to demonstrate 

IBIT’s position limit relative to other 

options symbols in terms of market 

capitalization and ADV. For reference, 

the market capitalization for IBIT was 

$46,783,480,800 20 with an ADV, for the 

preceding three months prior to 

November 25, 2024, of 39,421,877 

shares. 

Market cap 

statistics 25k 50k 75k 100k–<250k 250k–<500k 500k–1mm >1mm 

# of observations ... 562 473 651 240 1934 27 10 

average ................. 1,038,795,162 2,957,127,045 4,466,049,699 5,390,836,360 26,286,624,063 67,390,777,100 717,540,906,097 

median ................... 360,130,143 889,627,570 1,445,831,231 1,643,123,279 3,535,963,213 27,063,940,966 90,047,209,478 

min ......................... 2,204,436 4,211,156 3,830,532 5,090,230 1,616,094 2,762,394,749 11,786,645,969 

max ........................ 36,120,249,097 70,846,805,916 174,820,296,591 106,971,594,180 3,573,884,443,220 733,972,714,698 3,358,647,600,000 

IBIT % rank .... 100.00% 98.94% 98.77% 98.33% 88.57% 59.26% 20.00% 


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21The Exchange utilized Excel’s Data Analysis 

Package to model the position limit. 

22The Exchange utilized this formula to arrive at 

the number of contracts: ((46,783,380,800 mkt cap 

* 0.0000002630 market cap coefficient) + 

(39,421,877 ADV * 0.0140402219 ADV coefficient)). 

23See https://www.coingecko.com/en/coins/ 

bitcoin. 

24This is the approximate price of bitcoin from 

4:00 pm ET on November 25, 2024. 

25This percentage is arrived at with this equation: 

(250,000 contract limit * 100 shares per option/ 

866,040,000 shares outstanding). 

26This number was arrived at with this 

calculation: ((250,000 limit * 100 shares per option 

* $54.02 settle) / (19,787,762 BTC outstanding * 

$94,830 BTC price)). 

27CME Bitcoin Futures are described in Chapter 

350 of CME’s Rulebook. 

28See the Position Accountability and Reportable 

Level Table in the Interpretations & Special Notices 

Section of Chapter 5 of CME’s Rulebook. 

29 2,000 futures at a 5 bitcoin multiplier (per the 

contract specifications) equates to $949,450,000 

(2000 contracts * 5 BTC per contract * $94,945 

price of November BTC future) of notional value. 

30See https://www.cmegroup.com/education/ 

courses/market-regulation/position-limits/positionlimits-aggregation-of-contracts-and-table.htm. 

90-Day ADV 

statistics 25k 50k 75k 100k–<250k 250k–<500k 500k–1mm >1mm 

# of observations ... 562 473 651 240 1934 27 10 

average ................. 76,586 213,419 425,542 623,888 3,510,784 5,930,607 44,610,385 

median ................... 67,231 206,402 409,177 625,882 1,620,931 4,724,248 18,017,607 

min ......................... 4,791 10,084 18,191 105,713 16,276 1,207,242 1,771,544 

max ........................ 244,499 564,451 989,341 1,339,553 88,351,060 22,397,311 271,230,790 

IBIT % rank .... 100.00% 100.00% 100.00% 100.00% 99.43% 100.00% 80.00% 

Based on the above table, if IBIT were 

compared to the 1,934 stocks that have 

position limits of 250,000 contracts to 

less than 500,000 contracts it would 

rank in the 88th percentile for market 

capitalization and the 99th percentile 

for ADV. 

The Exchange also analyzed the 

position limits for IBIT by regressing the 

market capitalization figures and 90-day 

ADV of all non-ETF equities, against 

their respective position limit figures. 

From this regression, the Exchange was 

able to determine the implied 

coefficients to create a formulaic 

method for determining an appropriate 

position limit.21 In this case, the 

modeled position limit is 565,796 

contracts.22 The results of the study are 

below. 

REGRESSION STATISTICS

Multiple R .......................... 0.496800597 

R Square .......................... 0.246810833 

Adjusted R Square ........... 0.246361643 

Standard Error .................. 202227.4271 

Observations ..................... 3905 

ANOVA 

df SS MS F 

Regression ....................................................................................................... 2 5.2304E+13 2.6152E+13 639.482566 

Residual ........................................................................................................... 3903 1.5962E+14 4.0896E+10 ........................

Total .......................................................................................................... 3905 2.1192E+14 ........................ ........................

Coefficients Standard error t Stat P-value 

Intercept ........................................................................................................... 0 #N/A #N/A #N/A 

Market Cap ...................................................................................................... 0.0000002630 3.3371E–08 7.88130564 4.1699E–15 

90-day ADV ..................................................................................................... 0.0140402219 0.00055818 25.1533643 1.613E–129 

Based on the aforementioned analysis, 

the Exchange believes that the proposed 

250,000 contracts for position and 

exercise limits is appropriate. 

Second, ISE reviewed IBIT’s data 

relative to the market capitalization of 

the entire bitcoin market in terms of 

exercise risk and availability of 

deliverables. As of November 25, 2024, 

there are 19,787,762 bitcoins in 

circulation.23 At a price of $94,830,24

that equates to a market capitalization of 

greater than $1.876 trillion US. If a 

position limit of 250,000 contracts were 

considered, the exercisable risk would 

represent 2.89% 25 of the outstanding 

shares outstanding of IBIT. Since IBIT 

has a creation and redemption process 

managed through the issuer, the 

position limit can be compared to the 

total market capitalization of the entire 

bitcoin market and in that case, the 

exercisable risk for options on IBIT 

would represent less than .072% of all 

bitcoin outstanding.26 Assuming a 

scenario where all options on IBIT 

shares were exercised given the 

proposed 250,000 contract position 

limit (and exercise limit), this would 

have a virtually unnoticed impact on 

the entire bitcoin market. This analysis 

demonstrates that the proposed 250,000 

per same side position and exercise 

limit is appropriate for options on IBIT 

given its liquidity. 

Third, ISE reviewed the proposed 

position limit by comparing it to 

position limits for derivative products 

regulated by the Commodity Futures 

Trading Commission (‘‘CFTC’’). While 

the CFTC, through the relevant 

Designated Contract Markets, only 

regulates options positions based upon 

delta equivalents (creating a less 

stringent standard), ISE examined 

equivalent bitcoin futures position 

limits. In particular, ISE looked to the 

CME bitcoin futures contract 27 that has 

a position limit of 8,000 futures.28 On 

October 22, 2024, CME bitcoin futures 

settled at $94,945.29 On October 22, 

2024, IBIT settled at $54.02, which 

would equate to greater than 17,557,898 

shares of IBIT if the CME notional 

position limit was utilized. Since 

substantial portions of any distributed 

options portfolio is likely to be out of 

the money on expiration, an options 

position limit equivalent to the CME 

position limit for bitcoin futures 

(considering that all options deltas are 

<=1.00) should be a bit higher than the 

CME implied 175,578 limit. Of note, 

unlike options contracts, CME position 

limits are calculated on a net futuresequivalent basis by contract and include 

contracts that aggregate into one or more 

base contracts according to an 

aggregation ratio(s).30 Therefore, if a 


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31 Id. 

32 GLD, SLV and BITO each hold one asset in 

trust similar to IBIT. 

33See https://www.ssga.com/us/en/intermediary/ 

etfs/spdr-gold-shares-gld. 

34See https://www.ishares.com/us/products/ 

239855/ishares-silver-trust-fund. 

35See https://www.marketwatch.com/investing/ 

fund/bito. 

36MBTX is based on 1/10th the value of the Cboe 

Bitcoin U.S. ETF Index. 

37See https://www.cboe.com/tradable_products/ 

bitcoin-etf-index-options?utm_source=mcae&utm_

medium=email&utm_campaign=bitcoin_eft_

options_launch. Cboe’s website provides a product 

comparison chart indicating that CBTX and MBTX 

are permitted to trade FLEX as compared to spot 

bitcoin ETF options. See https://cdn.cboe.com/ 

resources/membership/Cboe_Bitcoin_US_ETF_

Options_Comparative_Overview.pdf?_

gl=1*1xmm04c*_up*MQ..*_ga*MTc0MjU1NzU1Ni

4xNzM0NTU2NTky*_ga_

5Q99WB9X71*MTczNDU1NjU5MC4xL

jAuMTczNDU1NjU5MC4wLjAuMA. 

38See Cboe Rule 8.32(a). The Exchange notes that 

given the multiplier and notional value of CBTX, 

the index has a position and exercise limit that 

equates to 1,000,000 contracts of in kind exposure 

to IBIT, which is more than 40 times greater than 

the exposure for options on IBIT at the current 

25,000 contract position and exercise limit. 

39The Exchange may add to the Penny Program 

a newly listed option class provided that (i) it is 

among the 300 most actively traded multiply listed 

option classes, as ranked by National Cleared 

Volume at OCC, in its first full calendar month of 

trading and (ii) the underlying security is priced 

below $200 or the underlying index is at an index 

level below $200. Any option class added under 

this provision will be added on the first trading day 

of the month after it qualifies and will remain in 

the Penny Program for one full calendar year, after 

which it will be subject to the Annual Review 

described in Supplementary Material .01(b) to 

Options 3, Section 3. The Exchange may add any 

option class to the Penny Program, provided that (i) 

it is among the 75 most actively traded multiply 

listed option classes, as ranked by National Cleared 

Volume at OCC, in the past six full calendar months 

of trading and (ii) the underlying security is priced 

below $200 or the underlying index is at an index 

level below $200. Any option class added under 

this provision will be added on the first trading day 

of the second full month after it qualifies and will 

remain in the Penny Program for the rest of the 

calendar year, after which it will be subject to the 

Annual Review as described in Supplementary 

Material .01(b) to Options 3, Section 3. See 

Supplementary Material .01 to ISE Options 3, 

Section 3. 

40See Securities Exchange Act Release No. 88532 

(April 1, 2020), 67 FR 19545, 19548 (April 7, 2020) 

(File No. 4–443) (Joint Industry Plan; Order 

Approving Amendment No. 5 to the Plan for the 

Purpose of Developing and Implementing 

Procedures Designed To Facilitate the Listing and 

Trading of Standardized Options To Adopt a Penny 

Interval Program) (‘‘Penny Approval Order’’). 

41 Id. at 19548. 

42The Options Clearing Corporation (‘‘OCC’’) 

through the Large option Position Reporting 

(‘‘LOPR’’) system acts as a centralized service 

provider for TPH compliance with position 

reporting requirements by collecting data from each 

Continued 

portfolio includes positions in options 

on futures, CME would aggregate those 

positions into the underlying futures 

contracts in accordance with a table 

published by CME on a delta equivalent 

value for the relevant spot month, 

subsequent spot month, single month 

and all month position limits.31 If a 

position exceeds position limits because 

of an option assignment, CME permits 

market participants to liquidate the 

excess position within one business day 

without being considered in violation of 

its rules. Additionally, if at the close of 

trading, a position that includes options 

exceeds position limits for futures 

contracts, when evaluated using the 

delta factors as of that day’s close of 

trading, but does not exceed the limits 

when evaluated using the previous 

day’s delta factors, then the position 

shall not constitute a position limit 

violation. Based on the aforementioned 

analysis, the Exchange believes that the 

proposed 250,000 contracts for position 

and exercise limits is appropriate. 

Fourth, ISE analyzed a position and 

exercise limit of 250,000 for IBIT against 

other options on ETFs with an 

underling commodity, namely SPDR 

Gold Shares (‘‘GLD’’), iShares Silver 

Trust (‘‘SLV’’), and ProShares Bitcoin 

ETF (‘‘BITO’’).32 GLD has a float of 

306.1 million shares 33 and a position 

limit of 250,000 contract. SLV has a 

float of 520.7 million shares,34 and a 

position limit of 250,000 contracts. 

Finally, BITO has 107.65 million shares 

outstanding 35 and a position limit of 

250,000 contracts. As previously noted, 

position and exercise limits are 

designed to limit the number of options 

contracts traded on the exchange in an 

underlying security that an investor, 

acting alone or in concert with others 

directly or indirectly, may control. A 

position limit exercise in GLD would 

represent 8.17% of the float of GLD; a 

position limit exercise in SLV would 

represent 4.8% of the float of SLV, and 

a position limit exercise of BITO would 

represent 23.22% of the float of BITO. 

In comparison, a 250,000 contract 

position limit in IBIT would represent 

2.89% of the float of IBIT. 

Consequently, the 250,000 proposed 

IBIT options position and exercise limit 

is more conservative than the standard 

applied to GLD, SLV and BITO, and 

appropriate. Additionally, the Exchange 

notes that the Cboe Bitcoin U.S. ETF 

Index Options (CBTX) and the Cboe 

Mini Bitcoin U.S. ETF Index Options 

(MBTX),36 which trade exclusively on 

Cboe, are comprised of multiple bitcoin 

ETFs of which IBIT is the highest 

weighted (at 20%) in the index 

composition.37 These indices currently 

trade pursuant to a 24,000 contract 

position and exercise limit.38

Fifth, ISE notes that IBIT is likely to 

trade in penny increments as of January 

2, 2025, provided it is able to meet the 

applicable criteria.39 The Commission 

noted that evidence contained in both 

the Exchanges’ Report and the 

Cornerstone analysis demonstrates that 

the Penny Pilot has benefitted investors 

and other market participants in the 

form of narrower spreads.40 The most 

actively traded options classes are 

included in the Penny Program based on 

certain objective criteria (trading 

volume thresholds and initial price 

tests). As noted in the Penny Approval 

Order, the Penny Program reflects a 

certain level of trading interest (either 

because the class is newly listed or a 

class that experience a significant 

growth in investor interest) to quote in 

finer trading increments, which in turn 

should benefit market participants by 

reducing the cost of trading such 

options.41 If IBIT options were to enter 

the Penny Program, it will be among a 

select group of products that have 

achieved a certain level of liquidity that 

have garnered it the ability to trade in 

finer increments. The Exchange believes 

that if IBIT options were to trade in 

penny increments, failing to increase 

position and exercise limits once it 

started trading in finer increments, may 

artificially inhibit liquidity and create 

price inefficiency. 

The Exchange believes that IBIT 

options has demonstrated that it has 

more than sufficient liquidity to garner 

an increased position and exercise limit 

of 250,000 contracts. The Exchange 

believes that any concerns related to 

manipulation and protection of 

investors are mollified by the significant 

liquidity provision in IBIT. The 

Exchange states that, as a general 

principle, increases in active trading 

volume and deep liquidity of the 

underlying securities do not lead to 

manipulation and/or disruption. 

The Exchange believes that increasing 

the position (and exercise) limits for 

IBIT options would lead to a more 

liquid and competitive market 

environment for IBIT options, which 

will benefit customers that trade these 

options. Further, the reporting 

requirement for such options would 

remain unchanged. Thus, the Exchange 

will still require that each member 

organization that maintains positions in 

impacted options on the same side of 

the market, for its own account or for 

the account of a customer, report certain 

information to the Exchange. This 

information includes, but would not be 

limited to, the options’ positions, 

whether such positions are hedged and, 

if so, a description of the hedge(s). 

Market-Makers would continue to be 

exempt from this reporting requirement, 

however, the Exchange may access 

Market-Maker position information.42


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TPH or TPH organization, consolidating the 

information, and ultimately providing detailed 

listings of each TPH’s report to the Exchange, as 

well as Financial Industry Regulatory Authority, 

Inc. (‘‘FINRA’’), acting as its agent pursuant to a 

regulatory services agreement (‘‘RSA’’). 

43See Options 9, Section 16. 

44 17 CFR 240.13d–1. 45See Options 9, Section 3 regarding margin 

requirements. 46 17 CFR 240.15c3–1. 47 15 U.S.C. 78f(b). 48 15 U.S.C. 78f(b)(5). 49 15 U.S.C. 78(f)(b)(5). 

50This percentage is arrived at with this equation: 

(250,000 contract limit * 100 shares per option/ 

866,040,000 shares outstanding). 

51This number was arrived at with this 

calculation: ((250,000 limit * 100 shares per option 

* $54.02 settle) / (19,787,762 BTC outstanding * 

$94,830 BTC price)). 

Moreover, the Exchange’s requirement 

that member organizations file reports 

with the Exchange for any customer 

who held aggregate large long or short 

positions on the same side of the market 

of 200 or more option contracts of any 

single class for the previous day will 

remain at this level and will continue to 

serve as an important part of the 

Exchange’s surveillance efforts.43

The Exchange also has no reason to 

believe that the growth in trading 

volume in IBIT will not continue. 

Rather, the Exchange expects continued 

options volume growth in IBIT as 

opportunities for investors to participate 

in the options markets increase and 

evolve. The Exchange believes that the 

current position and exercise limits in 

IBIT options are restrictive and will 

hamper the listed options markets from 

being able to compete fairly and 

effectively with the over-the-counter 

(‘‘OTC’’) markets. OTC transactions 

occur through bilateral agreements, the 

terms of which are not publicly 

disclosed to the marketplace. As such, 

OTC transactions do not contribute to 

the price discovery process on a public 

exchange or other lit markets. The 

Exchange believes that without the 

proposed changes to position and 

exercise limits for IBIT, market 

participants will find the 25,000 

contract position limit an impediment 

to their business and investment 

objectives as well as an impediment to 

efficient pricing. As such, market 

participants may find the less 

transparent OTC markets a more 

attractive alternative to achieve their 

investment and hedging objectives, 

leading to a retreat from the listed 

options markets, where trades are 

subject to reporting requirements and 

daily surveillance. 

The Exchange believes that the 

existing surveillance procedures and 

reporting requirements at the Exchange 

are capable of properly identifying 

disruptive and/or manipulative trading 

activity. The Exchange also represents 

that it has adequate surveillances in 

place to detect potential manipulation, 

as well as reviews in place to identify 

continued compliance with the 

Exchange’s listing standards. These 

procedures monitor market activity via 

automated surveillance techniques to 

identify unusual activity in both options 

and the underlyings, as applicable. The 

Exchange also notes that large stock 

holdings must be disclosed to the 

Commission by way of Schedules 13D 

or 13G,44 which are used to report 

ownership of stock which exceeds 5% 

of a company’s total stock issue and 

may assist in providing information in 

monitoring for any potential 

manipulative schemes. Further, the 

Exchange believes that the current 

financial requirements imposed by the 

Exchange and by the Commission 

adequately address concerns regarding 

potentially large, unhedged positions in 

equity options. Current margin and riskbased haircut methodologies serve to 

limit the size of positions maintained by 

any one account by increasing the 

margin and/or capital that a member 

organization must maintain for a large 

position held by itself or by its 

customer.45 In addition, Rule 15c3–1 46

imposes a capital charge on member 

organizations to the extent of any 

margin deficiency resulting from the 

higher margin requirement. 

2. Statutory Basis 

The Exchange believes that its 

proposal is consistent with Section 6(b) 

of the Act,47 in general, and furthers the 

objectives of Section 6(b)(5) of the Act,48

in particular, in that it is designed to 

prevent fraudulent and manipulative 

acts and practices, to promote just and 

equitable principles of trade, to foster 

cooperation and coordination with 

persons engaged in regulating, clearing, 

settling, processing information with 

respect to, and facilitating transactions 

in securities, to remove impediments to 

and perfect the mechanism of a free and 

open market and a national market 

system, and, in general, to protect 

investors and the public interest. 

Additionally, the Exchange believes the 

proposed rule change is consistent with 

the Section (6)(b)(5) 49 requirement that 

the rules of an exchange not be designed 

to permit unfair discrimination between 

customers, issuers, brokers, or dealers. 

The Exchange believes increasing the 

position (and exercise limits) for IBIT 

options from 25,000 to 250,000 

contracts will remove impediments to 

and perfect the mechanism of a free and 

open market and a national market 

system, and, in general, protect 

investors and the public interest, 

because it will provide market 

participants with the ability to more 

effectively execute their trading and 

hedging activities. Also, increasing the 

position (and exercise) limits for IBIT 

options may allow Market-Makers to 

maintain their liquidity in these options 

in amounts commensurate with the 

continued high consumer demand in 

IBIT options market. The proposed 

higher position and exercise limit may 

also encourage other liquidity providers 

to continue to trade on the Exchange 

rather than shift their volume to OTC 

markets, which will enhance the 

process of price discovery conducted on 

the Exchange through increased order 

flow. The Exchange notes that a higher 

position and exercise limit would 

further allow institutional investors to 

utilize IBIT options for prudent risk 

management purposes. 

In addition, the Exchange believes 

that the current liquidity in shares of 

and options on IBIT will mitigate 

concerns regarding potential 

manipulation of IBIT and/or disruption 

of IBIT upon increasing the position 

limit. ISE’s proposed position and 

exercise limit of 250,000 contracts on 

IBIT options is appropriate given the 

market capitalization and ADV of IBIT 

and designed to prevent fraudulent and 

manipulative acts and practices. If IBIT 

were compared to the 1,934 stocks that 

have position limits of 250,000 contracts 

to less than 500,000 contracts it would 

rank in the 88th percentile for market 

capitalization and the 99th percentile 

for ADV. 

Additionally, the regression model 

performed by ISE demonstrates that the 

proposed position limit is half of the 

modeled limit given the liquidity of 

IBIT. Comparing IBIT’s data relative to 

the market capitalization of the entire 

bitcoin market in terms of exercise risk 

and availability of deliverables, the 

Exchange was able to conclude that if a 

position limit of 250,000 contracts were 

considered, the exercisable risk would 

represent 2.89%50 of the shares 

outstanding of IBIT. Since IBIT has a 

creation and redemption process 

managed through the issuer (whereby 

Bitcoin is used to create IBIT shares), 

the position limit can be compared to 

the total market capitalization of the 

entire bitcoin market and in that case, 

the exercisable risk for options on IBIT 

would represent less than .072% of all 

bitcoin outstanding.51 Comparing the 

proposed position limit to position 

limits for equivalent bitcoin futures 

position limits, the analysis 

demonstrated that the proposed 250,000 


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52See https://www.cboe.com/tradable_products/ 

bitcoin-etf-index-options?utm_source=mcae&utm_

medium=email&utm_campaign=bitcoin_eft_

options_launch. 

53See Cboe Rule 8.32(a). The Exchange notes that 

given the multiplier and notional value of CBTX, 

the index has a position and exercise limit that 

equates to 1,000,000 contracts of in kind exposure 

to IBIT, which is more than 40 times greater than 

the exposure for options on IBIT at the current 

25,000 contract position and exercise limit. 

54 18,000 contracts is the lowest position limit for 

industry index options if the Exchange determines, 

at the time of a review conducted pursuant to 

subparagraph (2) of this paragraph (a), that any 

single underlying stock accounted, on average, for 

thirty percent (30%) or more of the index value 

during the thirty (30) -day period immediately 

preceding the review. See ISE Options 4A, Section 

7. Further, Cboe Rule 8.32(a)(3) permits a limit of 

31,500 contracts if the Exchange determines that the 

conditions specified in Rule 8.32(a)(1) and (2), 

which would require the establishment of a lower 

limit, have not occurred. 

55The Exchange may add to the Penny Program 

a newly listed option class provided that (i) it is 

among the 300 most actively traded multiply listed 

option classes, as ranked by National Cleared 

Volume at OCC, in its first full calendar month of 

trading and (ii) the underlying security is priced 

below $200 or the underlying index is at an index 

level below $200. Any option class added under 

this provision will be added on the first trading day 

of the month after it qualifies and will remain in 

the Penny Program for one full calendar year, after 

which it will be subject to the Annual Review 

described in Supplementary Material .01(b) to 

Options 3, Section 3. The Exchange may add any 

option class to the Penny Program, provided that (i) 

it is among the 75 most actively traded multiply 

listed option classes, as ranked by National Cleared 

Volume at OCC, in the past six full calendar months 

of trading and (ii) the underlying security is priced 

below $200 or the underlying index is at an index 

level below $200. Any option class added under 

this provision will be added on the first trading day 

of the second full month after it qualifies and will 

remain in the Penny Program for the rest of the 

calendar year, after which it will be subject to the 

Annual Review as described in Supplementary 

Material .01(b) to Options 3, Section 3. See 

Supplementary Material .01 to ISE Options 3, 

Section 3. 

56See Securities Exchange Act Release No. 88532 

(April 1, 2020), 85 FR 19545, 19548 (April 7, 2020) 

(File No. 4–443) (Joint Industry Plan; Order 

Approving Amendment No. 5 to the Plan for the 

Purpose of Developing and Implementing 

Procedures Designed To Facilitate the Listing and 

Trading of Standardized Options To Adopt a Penny 

Interval Program) (‘‘Penny Approval Order’’). 

57 Id. at 19548. 

contracts for position and exercise 

limits is appropriate. 

Comparing a position limit of 250,000 

for IBIT against other options on ETFs 

with an underling commodity, namely 

GLD, SLV and BITO, a position limit 

exercise in GLD represents 8.17% of the 

float of GLD, a position limit exercise in 

SLV represents 4.8% of the float of SLV, 

and a position limit exercise of BITO 

represents 23.22% of the float of BITO. 

In comparison, a 250,000 contract 

position limit in IBIT would represent 

2.89% of the float of IBIT. 

Consequently, the 250,000 proposed 

IBIT options position limit is more 

conservative than the standard applied 

to GLD, SLV and BITO, and appropriate. 

Also, the Exchange notes that Cboe’s 

proprietary CBTX and MBTX indices 

weight IBIT the highest (at 20%) in its 

index composition among the other 

ETFs that comprise the index.52 The 

Exchange notes that today, these 

indexes have a position of 24,000 

contracts which is much higher than the 

current position limits for IBIT options 

when considering the notional value of 

the indices.53 These indexes are already 

trading with position and exercise limits 

that are higher than the lowest position 

limit for an industry index option.54

ISE notes that IBIT is likely to trade 

in penny increments in January 2025, 

provided it is able to meet the 

applicable criteria.55 The Commission 

noted that evidence contained in both 

the Exchanges’ Report and the 

Cornerstone analysis demonstrates that 

the Penny Pilot has benefitted investors 

and other market participants in the 

form of narrower spreads.56 The most 

actively traded options classes are 

included in the Penny Program based on 

certain objective criteria (trading 

volume thresholds and initial price 

tests). As noted in the Penny Approval 

Order, the Penny Program reflects a 

certain level of trading interest (either 

because the class is newly listed or a 

class that experience a significant 

growth in investor interest) to quote in 

finer trading increments, which in turn 

should benefit market participants by 

reducing the cost of trading such 

options.57 If IBIT options were to enter 

the Penny Program, it will be among a 

select group of products that have 

achieved a certain level of liquidity that 

have garnered it the ability to trade in 

finer increments. The Exchange believes 

that if IBIT options were to trade in 

penny increments, failing to increase 

position and exercise limits once it 

started trading in finer increments, may 

artificially inhibit liquidity and create 

price inefficiency. 

Finally, as discussed above, the 

Exchange’s surveillance and reporting 

safeguards continue to be designed to 

deter and detect possible manipulative 

behavior that might arise from 

increasing or eliminating position and 

exercise limits in certain classes. The 

Exchange believes that the current 

financial requirements imposed by the 

Exchange and by the Commission 

adequately address concerns regarding 

potentially large, unhedged positions in 

the options on the underlying securities, 

further promoting just and equitable 

principles of trading, the maintenance 

of a fair and orderly market, and the 

protection of investors. 

B. Self-Regulatory Organization’s 

Statement on Burden on Competition 

The Exchange does not believe that 

the proposed rule change will impose 

any burden on competition that is not 

necessary or appropriate in furtherance 

of the purposes of the Act. 

The Exchange’s proposal does not 

burden intra-market competition 

because all Members would be 

permitted to trade IBIT options pursuant 

to the proposed position and exercise 

limit of 250,000 contracts. The 

Exchange believes that the proposed 

rule change will also provide additional 

opportunities for market participants to 

continue to efficiently achieve their 

investment and trading objectives for 

equity options on the Exchange. 

The Exchange does not believe that 

the proposed rule change will impose 

any burden on inter-market competition 

as the proposal is not competitive in 

nature. The Exchange expects that all 

option exchanges will adopt 

substantively similar proposals for 

adopting the additional position limit 

tiers, such that the Exchange’s proposal 

would benefit competition. For these 

reasons, the Exchange does not believe 

that the proposed rule change will 

impose any burden on competition not 

necessary or appropriate in furtherance 

of the purposes of the Act. 

C. Self-Regulatory Organization’s 

Statement on Comments on the 

Proposed Rule Change Received From 

Members, Participants, or Others 

No written comments were either 

solicited or received. 

III. Date of Effectiveness of the 

Proposed Rule Change and Timing for 

Commission Action 

Within 45 days of the date of 

publication of this notice in the Federal 

Register or within such longer period 

up to 90 days (i) as the Commission may 

designate if it finds such longer period 

to be appropriate and publishes its 

reasons for so finding or (ii) as to which 

the self-regulatory organization 

consents, the Commission will: 

(A) by order approve or disapprove 

such proposed rule change, or 

(B) institute proceedings to determine 

whether the proposed rule change 

should be disapproved. 

IV. Solicitation of Comments 

Interested persons are invited to 

submit written data, views and 

arguments concerning the foregoing, 

including whether the proposed rule 

change is consistent with the Act. 

Comments may be submitted by any of 

the following methods: 


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58 17 CFR 200.30–3(a)(12). 

1 15 U.S.C. 78s(b)(1). 

2 17 CFR 240.19b–4. 

3See Notice of Filing infra note 4, at 89 FR 81958. 

4See Securities Exchange Act Release No. 101246 

(Oct. 3, 2024), 89 FR 81958 (Oct. 9, 2024) (File No. 

SR–OCC–2024–014) (‘‘Notice of Filing’’). 

5 15 U.S.C. 78s(b)(2). 

6See Securities Exchange Act Release No. 101684 

(Nov. 21, 2024), 89 FR 93693 (Nov. 27, 2024) (File 

No. SR–OCC–2024–014). 

7Capitalized terms used but not defined herein 

have the meanings specified in OCC’s Rules and ByLaws, available at https://www.theocc.com/about/ 

publications/bylaws.jsp. 

8See Securities Exchange Act Release No. 78961 

(Sep. 28, 2016), 81 FR 70786, 70819 (Oct. 13, 2016) 

(‘‘Standards for Covered Clearing Agencies’’) 

(stating that a covered clearing agency generally 

should consider, among other things, ‘‘whether 

initial margin meets an established single-tailed 

confidence level of at least 99 percent with respect 

to the estimated distribution of future exposure[.]’’). 

9See Securities Exchange Act Release No. 91079 

(Feb. 8, 2021), 86 FR 9410 (Feb. 12, 2021) (File No. 

SR–OCC–2020–016) (‘‘STANS Methodology 

Approval’’). 

10See Notice of Filing, notes 25–28 (describing 

the parameters to which bounds are applied). 

Electronic Comments 

• Use the Commission’s internet 

comment form (https://www.sec.gov/ 

rules/sro.shtml); or 

• Send an email to rule-comments@

sec.gov. Please include file number SR– 

ISE–2024–62 on the subject line. 

Paper Comments 

• Send 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–ISE–2024–62. This file 

number should be included on the 

subject line if email is used. To help the 

Commission process and review your 

comments more efficiently, please use 

only one method. The Commission will 

post all comments on the Commission’s 

internet website (https://www.sec.gov/ 

rules/sro.shtml). Copies of the 

submission, all subsequent 

amendments, all written statements 

with respect to the proposed rule 

change that are filed with the 

Commission, and all written 

communications relating to the 

proposed rule change between the 

Commission and any person, other than 

those that may be withheld from the 

public in accordance with the 

provisions of 5 U.S.C. 552, will be 

available for website viewing and 

printing in the Commission’s Public 

Reference Room, 100 F Street NE, 

Washington, DC 20549, on official 

business days between the hours of 10 

a.m. and 3 p.m. Copies of the filing also 

will be available for inspection and 

copying at the principal office of the 

Exchange. Do not include personal 

identifiable information in submissions; 

you should submit only information 

that you wish to make available 

publicly. We may redact in part or 

withhold entirely from publication 

submitted material that is obscene or 

subject to copyright protection. All 

submissions should refer to file number 

SR–ISE–2024–62 and should be 

submitted on or before January 27, 2025. 

For the Commission, by the Division of 

Trading and Markets, pursuant to delegated 

authority.58

Stephanie J. Fouse, 

Assistant Secretary. 

[FR Doc. 2024–31771 Filed 1–3–25; 8:45 am] 

BILLING CODE 8011–01–P 

SECURITIES AND EXCHANGE 

COMMISSION 

[Release No. 34–102057; File No. SR–OCC– 

2024–014] 

Self-Regulatory Organizations; The 

Options Clearing Corporation; Order 

Granting Approval of Proposed Rule 

Change, as Modified by Partial 

Amendment No. 1, by The Options 

Clearing Corporation Concerning Its 

Process for Adjusting Certain 

Parameters in Its Proprietary System 

for Calculating Margin Requirements 

During Periods When the Products It 

Clears and the Markets It Serves 

Experience High Volatility 

December 30, 2024. 

I. Introduction 

On October 1, 2024, the Options 

Clearing Corporation (‘‘OCC’’) filed with 

the Securities and Exchange 

Commission (‘‘Commission’’) the 

proposed rule change SR–OCC–2024– 

014, pursuant to Section 19(b) of the 

Securities Exchange Act of 1934 

(‘‘Exchange Act’’) 1 and Rule 19b–4 2

thereunder, to codify OCC’s process for 

adjusting certain parameters in its 

proprietary system for calculating 

margin requirements during periods 

when the products OCC clears and the 

markets it serves experience high 

volatility.3 The proposed rule change, as 

modified by Partial Amendment No. 1 

(hereinafter, the ‘‘Proposed Rule 

Change’’) was published for public 

comment in the Federal Register on 

October 9, 2024.4 The Commission has 

received no comments regarding the 

Proposed Rule Change. 

On November 21, 2024, pursuant to 

Section 19(b)(2) of the Exchange Act,5

the Commission designated a longer 

period within which to approve, 

disapprove, or institute proceedings to 

determine whether to disapprove the 

Proposed Rule Change.6 For the reasons 

discussed below, the Commission is 

approving the Proposed Rule Change. 

II. Background 7

OCC is a central counterparty 

(‘‘CCP’’), which means that as part of its 

function as a clearing agency, it 

interposes itself as the buyer to every 

seller and the seller to every buyer for 

financial transactions. As the CCP for 

the listed options markets and for 

certain futures in the United States, 

OCC is exposed to the risk that one or 

more of its Clearing Members may fail 

to make a payment or to deliver 

securities. OCC addresses such risk 

exposure, in part, by requiring its 

Clearing Members to provide collateral, 

including margin collateral. Margin is 

the collateral that CCPs collect to cover 

potential changes in a member’s 

positions over a set period of time. 

Typically, margin is designed to cover 

such exposures during normal market 

conditions, which means that margin 

collateral should be sufficient to cover 

exposures at least 99 out of 100 days.8

OCC’s methodology for calculating 

margin collateral—including daily and 

intra-day margin requirements for 

Clearing Members—is a collection of 

margin models collectively called the 

System for Theoretical Analysis and 

Numerical Simulations (‘‘STANS’’). The 

STANS Methodology Description is a 

document that comprehensively 

describes the material aspects of OCC’s 

risk-based margin system, including its 

approach for calculating daily and intraday margin requirements for its Clearing 

Members.9

As a collection of models, STANS is 

subject to assumptions and limitations 

that are incorporated into STANS as 

margin model parameters. For example, 

OCC has a price return model that 

employs bounds, or ‘‘control sets’’ that 

are implemented under either regular or 

high volatility settings, for certain 

parameters that are calculated daily 

based on current market data.10 OCC 

maintains authority under its rules to 

adjust member margin requirements to 

protect the respective interests of OCC, 

its Clearing Members, and the public. 

OCC has established an exception 

process for implementing, changing, 

and terminating certain of these margin 

model parameters in STANS to control 

margin requirements where such 

parameters cause STANS to produce 

inappropriate margin requirements 


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