The CBOE ProCustomer rule has nothing to do with brokerage ProC customer designation. You are effectively a low-power market maker and have responsibilities as such. You'll need a clearing firm or go self-clearing. - not a broker. You'll have to file as a b/d or join one. You will have the expenses of an MM. What I don't know is the quoting requirement. Generally, the most difficult part is building the kill switch. Most of the applications and approved have target SPX or VIX. Focus report and the entire regulatory regiment.
Interesting, I had thought that when you get the Pro Customer designation when you trade over the 390 average, this would entitle you to be on both sides of the market. This is what I was told by my firm. So you are saying this is not true?