CBOE Futures Exchange issued amended guidance related to its electronic audit trail requirements for trading privilege holders (TPH), including a TPH’s obligations regarding the designation of one or more responsible traders, order entry operator IDs, audit trail and other books and records, and other compliance obligations. Among other things, every order and quote from a TPH must contain an Order Entry Operator ID. These IDs represent either the natural person ultimately responsible for directly or indirectly entering the order into the CFE matching system or an automated trading system that interfaces with the CFE (i.e., a system that automates the generation and routing of orders or quotes). An Order Entry Operator ID issued for one ATS may only be used for that ATS and may not be used for any natural person. Each clearing member must maintain or cause to be maintained front-end audit trail information for each TPH for which the clearing member is identified in the order or quote as responsible for the potential trade.
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