CBOE Holdings and its exchanges have adopted formal policies to enhance existing conflict of interest polices and practices - i.e., designed to ensure that the CBOE Regulatory Services Division performs its regulatory functions absent any conflicts of interest.  This includes  actual or perceived business interests of any CBOE company or any regulated person or entity.

Under the new policies, Trading Permit Holders and persons associated with TPHs should not discuss issues, questions or complaints about regulatory matters with directors and non-regulatory personnel of any CBOE company.

In particular, to avoid even the appearance that the Regulatory Services Division might be influenced by business interests, and subject to certain exceptions, the policies prohibit:

• directors and non-regulatory employees of a CBOE company from discussing any issues related to regulatory matters with CBOE regulatory personnel. 
• directors and non-regulatory personnel of CBOE companies from communicating with CBOE's regulatory personnel about issues, questions or complaints that a regulated entity or person has raised about regulatory matters.
• non-regulatory personnel from providing any guidance or advice regarding a regulatory matter.

Regulatory Matters are defined to ...  included regulatory investigations, exams or complaints either from or about a regulated entity or person concerning existing or anticipated regulatory actions and all investigative and surveillance activities of the Regulatory Services Division. 

Regulatory matters do not include activities related to potential legislation, rule-making or general regulatory policies that do not include specific facts about existing or anticipated regulatory investigations, examinations or actions.   [CBOE RegCirc 11-94, 8/4/11]