The CBOE Futures Exchange ("CFE") was launched in March 2004 and is a wholly-owned subsidiary of CBOE. This fully electronic contract market is registered with the Commodity Futures Trading Commission (CFTC). Although the product line is primarily stock-index futures contracts, CFE transactions clear at The Options Clearing Corporation (OCC). CFE is charged with enforcing the compliance of CFE Trading Privilege Holders ("TPH") and related parties with the Commodity Exchange Act and rules thereunder, the Securities Exchange Act and rules thereunder and CFE rules. Most CFE surveillances have been allocated to the National Futures Association ("NFA") pursuant to a Regulatory Services Agreement ("RSA"). Potential CFTC Core Principles violations or CFE rules violations uncovered by NFA through its surveillances are referred to the CFE Regulation (CFER) staff for further investigation and for regulatory and disciplinary resolution. The CFER staff also performs the CFE surveillance, examination and investigative functions that are not covered under the RSA (e.g., quoting reviews, intra-day monitoring, VIX expiration review and audit trail examinations). Regardless of whether investigations arise from an NFA process or internal CFE process, CFE maintains the responsibility to present potential violations to the Exchange's Business Conduct Committee to determine appropriate disciplinary action.