By 3/1/12, Trading Permit Holders of the CBOE, CBSX and C2 Exchanges must submit their Annual ITSFEA Rule 4.18 filings.   CBOE and C2 Exchange Rules 4.18 require every Trading Permit Holder (“TPH”) and every TPH Organization of CBOE, CBSX and of C2 to establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material nonpublic information by the TPH or persons associated with the TPH. To help individuals and small organizations comply with the record keeping requirements of these Rules, the Exchanges created a set of forms.  TPHs must meet the following guidelines to solely use the OE-418 forms:

• Individual TPHs with no employees;
• Individual TPHs who employ no more than 3 non-TPH employees;
• TPH organizations with no more than 3 nominees/registered for and which employ no more than 6 non-TPH employees.

The definition of “non-TPH employee” has been clarified to include all associated persons.  In turn, "person associated with a broker or dealer" or "associated person of a broker or dealer" means any partner, officer, director, or branch manager of such broker or dealer (or any person occupying a similar status or performing similar functions), any person directly or indirectly controlling, controlled by, or under common control with such broker or dealer, or any employee of such broker or dealer, except that any person associated with a broker or dealer whose functions are solely clerical or ministerial shall not be included in the meaning of such term for purposes of section 15(b) (other than paragraph (6) thereof). CBOE Staff Contacts. Forms, which are due by 3/1/12, can be accessed on the CBOE TPH website at:  www.cboe.org/GeneralInfo.  Or, contact Pat Sizemore (sizemore@cboe.com;  (312) 786-7752) for a copy of the form, or for answers to questions. For further details:  [CBOE RegCirc 12-24, C2 RegCirc 12-8, 2/1/12].