Options Regulatory Services Authority (ORSA)

In June 2006, the U. S. Securities and Exchange Commission ("SEC") approved the National Market System plan entered into by the (then) six (6) U.S. options exchanges (American Stock Exchange, Boston Stock Exchange, CBOE, International Securities Exchange, NYSE Arca and Philadelphia Stock Exchange) providing for the creation of the Options Regulatory Surveillance Authority ("ORSA"). ORSA was established to provide efficiencies in looking for insider trading and it serves as a central organization to facilitate collaboration in insider trading surveillance and investigations for the U.S. options exchanges. NASDAQ Options Markets, BATS Exchange, C2, NASDAQ OMX BX, Inc. and the Miami International Securities Exchange joined ORSA upon approval as options exchanges. ORSA is now responsible for conducting insider trading investigations on behalf of all eleven (11) options exchanges. CBOE has been chosen as the Regulatory Services Provider for ORSA.

Using a robust web-based application, ORSA staff is responsible for detecting trading in advance of the release of non-public corporate information as well as research reports, analyst recommendations, and market rumors by corporate officers, directors or employees of a publicly traded company or public investors. Possible insider trading effected by non-CBOE and non-C2 trading permit holders is generally referred to the SEC, while activity effected by CBOE or C2 trading permit holders is referred to the CBOE or C2 Business Conduct Committee, as may be applicable. ORSA staff is in continual communication with the SEC, other U.S and foreign governmental agencies and other exchanges to coordinate investigations across marketplaces. ORSA staff has also provided expertise and has served as an expert witness in cases prosecuted by the U.S. Attorney's Office. As part of the March 2012 re-organization of the Regulatory Services Division, ORSA was separated into a discrete Department within the Regulatory Division.