Cboe BZX has changed how annual listing fees are capped for Outcome Strategy exchange-traded products. Its 28 October filing, SR-CboeBZX-2026-090, replaces a single $16,000 annual cap with two tiers: $16,000 where a series contains four or fewer qualifying products and $25,000 where a series contains five or more. The rule also counts products whose outcome periods start in different calendar years as separate series for this purpose.[1]
Cboe lists SR-CboeBZX-2026-090 under approved or immediately effective rule changes. That combined register category should not be read as a separate SEC approval order or an invoice start date. The amendment concerns Outcome Strategy ETP series, so issuers need the operative schedule and their product classifications when calculating a charge.[1]
How the amended cap applies
| Qualifying series | Revised annual cap | Important condition |
|---|---|---|
| Four or fewer Outcome Strategy ETPs | $16,000 | Specific series as defined by ruleSource 1 |
| Five or more Outcome Strategy ETPs | $25,000 | Threshold changes the cap, not a retail commissionSource 1 |
| Different outcome-start years | Separate series | Cannot aggregate automatically across yearsSource 1 |
A product series is not simply an issuer's entire range
The start year is now part of the grouping calculation. Products whose outcome periods begin in different calendar years are counted as separate series even if they sit within one issuer’s broader range. That can change how many caps apply as well as which of the two thresholds each series meets.[1]
The direct commercial customer of an exchange listing-fee schedule is the issuer or listing sponsor. An issuer may consider such costs when budgeting a fund range, but a charge to the issuer does not establish that a fund shareholder will pay an identically sized fee or that its expense ratio automatically changes. Underlying fund terms and broker tariffs remain separate documents.[1][2]
How to compare the revised caps
At four eligible products, the specified maximum remains $16,000. At five, the cap becomes $25,000, a $9,000 higher ceiling. It is not necessarily a $9,000 incremental invoice because the cap is a maximum and the ordinary listing schedule determines how individual charges accumulate. A comparison must hold the same issuer, series definition, effective dates and qualifying count constant.[1]
For a product sponsor, the practical work is to map each qualifying ETP to its outcome-period start year, count the members of each series and compare accumulated listing charges with the applicable ceiling. That exercise identifies the issuer’s cost; a fund expense ratio or broker commission remains governed by separate terms.[1][2]
Sources & further reading
- BZX rule filing SR-CboeBZX-2026-090, Outcome Strategy ETP listing fees Cboe BZX · 28 Oct 2026 · Accessed 30 Oct 2026
- BZX equities fee and listing information Cboe · Accessed 30 Oct 2026