CBOE has the following individuals named in their regulatory circulars pertaining to the various rules, and amendments:
Christopher Hill, Legal Division, 312-786-7031.
Anthony Montesano, 312, 786-7365
Tom Knorring, 312-786-7363
Don Patton 312-786-7026
These individuals may only be available for member firms and their representatives to contact. But I will call them this week and ask if they are willing to discuss this amicably. Maybe they will not be concerned enough to do so. But with the public's perception of wall street and related institutions and this bear market, maybe they will be more amenable. But of course they do have the typically biased SEC on their side; an institution that seems to do little for the investor/trader without a major act of God; but much more for their cronies and former employers on the institutional side of the Street.
Other ETs might also decide to place a phone call or send a letter to the Office of the Chairman (CBOE), their Financial Planning Committee and/or their legal department.
Might as well start at the exchange level before seeking out a Chicago securities firm/attorney as counsel in this matter, or lobbying the SEC etc.
First you have a PDT rule that is absurd (although it has not affected me much but is still an impediment); then the PDT rule is applied to options! And the SEC continues to allow this rank discrimination to go on and on. Hard to have any respect for those guys (as if they have scruples to care what the off- floor trading "public" thinks anyway!)
What's interesting is the options exchanges apparently put up no fuss about the PDT rule application to options. In some regards one might think it would have some effect on volume albeit small perhaps. Apparently not enough in this bear to make a difference for them.
We might think that IF someone is willing to take the risk of significant loss in trading stocks and more so with options they ought to be allowed to do so without further impediment from the exchanges that are there to make markets for all (in theory).
Come on BOX... now's your chance.
Ice
b.t.w. at one time CBOE was actually charging member firms for "partial fills', thereby considering the balance of such orders "cancellations" under the definition in the Rule. Apparently that was changed in January and member firms were allowed to seek refunds.