Exchange fees are going to always be paid by someone in the equation - what you are sending is a "preferenced order" and in the index complex at CBOE those are worth their weight in gold.
Doesn't need to go on the form 605/605 and 607 is as vague as possible because it's not hard payment. If I'm a size MM and I could get preferencing from 3 or 4 brokers it's worth a fortune, especially if there is only one destination. You should discuss preferencing with your broker if you want to understand more.
Think of Etrade and Morgan Stanley. Essentially internalization and no checks get written.