April 6, 2020

Ms. Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re: Cboe Exchange, Inc.; Notice of Filing of a Proposed Rule Change To Increase Position Limits for Options on Certain Exchange-Traded Funds (‘‘ETFs’’) and Indexes (File No. SR–CBOE–2020–015)

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment upon the above-referenced filing (the “Filing” or the “Cboe Filing”) made by Cboe Exchange, Inc. (“Cboe” or “Exchange”) with the Securities and Exchange Commission (“SEC” or the “Commission”). In the Filing, Cboe proposes to amend Exchange Rules 8.30 and 8.31, Position Limits, to increase the position limits for options on six (6) underlying Exchange Traded Funds (“ETFs”) as well as two Indexes (the “Indexes”) (together, the “Proposal”).

SIFMA recommends that the Commission approve Cboe’s Proposal to increase the position limits for the options on the ETFs and Indexes as set forth therein, and respectfully submits this comment letter in response to the SEC’s solicitation of comments. As discussed below, SIFMA believes that the arguments underlying Cboe’s Proposal support its approval by the Commission as it relates to the symbols referenced in filing SR-CBOE-2020-15.

As an initial matter, SIFMA observes that Cboe’s analysis is correct with respect to the continuously increasing market capitalization of the Underlying ETFs, the ETF component securities, and the component securities of the Underlying Indexes, under normal market conditions. This market capitalization should mitigate any concern about potential manipulation and/or disruption in the underlying markets upon increasing position limits.2 Cboe’s arguments are also accurate with respect to the highly liquid markets for the underlying securities, even to the extent that trading in such securities is presenting somewhat differently during the current market volatility The rising demand for trading options on the Underlying ETFs and Indexes suggests legitimate market need for an increase in position limits. As Cboe observes, increasing position limits would enable liquidity providers to provide additional liquidity to the Exchange, and enable other market participants to transfer their liquidity demands from OTC markets to the Exchange and other options exchange on which they participate. Conversely, as Cboe correctly points out, failing to adjust position limits for options on these ETFs and Indexes will likely continue to impede trading activity and strategies of investors, such as use of effective hedging vehicles or income generating strategies, and the ability of Market-Makers to make liquid markets with tighter spreads in these options.