SEC Division of Trading and Markets no-action letter: Letter from Cboe Europe

Katten Muchin Rosenman UK LLP is a Limited Liability Partnership of solicitors and registered foreign lawyers registered in England & Wales, authorised and regulated by the Solicitors Regulation Authority, whose registered office is at Paternoster House, 65 St. Paul's Churchyard, London EC4M 8AB. Registered No. OC312814. A list of the members of Katten Muchin Rosenman UK LLP is available for inspection at the registered office. We use the word “partner” to refer to a member of the LLP. Katten Muchin Rosenman UK LLP of England & Wales is associated with Katten Muchin Rosenman LLP, a US Limited Liability Partnership with offices in:
CENTURY CITY CHARLOTTE CHICAGO DALLAS LOS ANGELES NEW YORK ORANGE COUNTY SHANGHAI WASHINGTON, DC Paternoster House 65 St Paul's Churchyard London, EC4M 8AB +44 (0) 20 7776 7620 tel +44 (0) 20 7776 7621 fax www.katten.co.uk carolyn.jackson@katten.co.uk +44 (0) 20 7776 7625 direct Ref No. 394348 00003 CHJ:cw January 30, 2026 VIA E-MAIL Mr. Jamie Selway Director Division of Trading and Markets U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549-7010 United States of America Re: Termination of Reliance by Cboe Europe B.V. on No-Action Relief for Foreign Options Markets and Their Members that Engage in Familiarization Activities Dear Mr. Selway:
We write on behalf of our client, Cboe Europe B.V. (“Cboe Europe”), further to prior notifications submitted to the Securities and Exchange Commission’s (“SEC”) Division of Trading and Markets (“Division”) regarding Cboe Europe’s reliance on the class no-action relief for foreign options markets and their members engaging in familiarisation activities with certain U.S.-based persons 1 as detailed in our letter dated September 1, 2021 to the Division 2 and our letter dated May 23, 2023 to the Division. 3 At Cboe Europe’s request, we write to provide formal notice that Cboe Europe will cease relying on the Class Relief as of close of business on Monday, February 23, 2026 (“End Date”). This notice follows Cboe Europe’s decision to wind down its Cboe Europe Derivatives (“CEDX”) exchange service, with participants having been informed of the timeline for an orderly market closure. As part of this process, all remaining open positions on CEDX will be supported to close in an orderly manner, in line with the milestones published in the participant 1 See LIFFE A&M and Class Relief, SEC No-Action Letter (July 1, 2013) (“Class Relief”). 2 Letter from Carolyn H. Jackson, Katten, to Mr. David Saltiel, Acting Director, Division, Commission, dated, September 1, 2021. 3 Letter from Carolyn H. Jackson, Katten, to Mr. Haoxiang Zhu, Director, Division, Commission, dated, May 23, 2023.

January 30, 2026
15734161v3 notice issued on Friday, January 9, 2026 (enclosed). The End Date aligns with CEDX’s decommissioning and the cessation of any logical connectivity into the environment. We note that any remaining open positions will be cash‑settled at fair market value on Friday, February 20, 2026. Should Cboe Europe in the future seek to re‑engage in familiarization activities under the Class Relief, it understands that it must submit a new notification letter to the Division pursuant to the terms of the Class Relief.

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We would be pleased to answer any questions that you or the Division might have regarding this letter. Please feel free to contact me at + 44 207 776 7625 or at carolyn.jackson@katten.co.uk. Sincerely, Carolyn H. Jackson
cc. Mr. Richard Holley III, Assistant Director - U.S. Securities and Exchange Commission
encls: Participant notice