美国期权交易所已设定规则，把交易行为被视为“专业”（即交易方式更类似于做市商而非普通客户的个人或实体）的一批公众客户（即并非经纪交易商）委托单，与交易行为并非“专业”的公众客户区分开来。 根据该等细则，任何不是经纪交易商的客户，但在每季度的最少1个月内，每日平均下达超过390笔美国上市期权委托单（在其自有受益账户），将被分类为专业。

代专业客户提交的委托单在执行优先级和费用方面与经纪交易商待遇相同。 

经纪商需最少每个季度进行一次审查，以确定该季度内的任意月份，哪些客户超过了390笔委托单的临界值，以及哪些客户将在下一个季度被指定为专业。

委托单计算

各地交易所对委托单的定义略有不同，寻求特定期权计算规则的客户（特别是使用算法委托单类型时，在某些情况下，可能导致在市场两边下达委托单）应查看相关交易所的规则手册和指南。然而，为达到计算期权委托单的目的，委托单通常被定义为：

• 单一委托单；
• 8条或以下期权边的复杂委托单；
• 在一个9条或以上期权边的复杂委托单中的每条期权边；或
• 母委托单，即使该委托单被经纪商分割为多笔同边/系列的子委托单，以达到执行或传递目的 （挂钩全国最佳买卖报价（NBBO）的委托单除外，下方会加以说明）。 

根据上方的逻辑，由客户发起的取消和取代母委托单（通过任意方式，如分段委托单）会计算为新委托单（如取消/取代一笔单边委托单会计算为一笔新委托单，而取消/取代一笔9条期权边的委托单会计算为9笔新委托单）。 

挂钩全国最佳买卖报价（NBBO）/最佳买卖报价（BBO）的委托单

请注意，使用挂钩NBBO或BBO期权委托单的客户（如相对委托单或挂钩波幅委托单，或其它母委托单类型，其设计是跟随NBBO/BBO移动），每笔基于NBBO/BBO改变而取消/取代的子委托单，将构成一笔额外新委托单。 把挂钩委托单存放在IBUSOPT以参与RFQ竞价的客户应留意，每次挂钩委托单在IBKR系统参与RFQ竞价时，将以取消并取代的方式处理（无论该委托单是否成为交易所竞价的发起委托单）。 

账户集合

在计算委托单总数时，经纪商必须把客户全部实益拥有账户的期权委托单加起来。 IBKR把个人或实体账户的期权委托单与其相关的联名账户、信托账户和组织账户加起来。

如客户身份由零售客户转变为专业客户，IBKR将向其发出通知。此外，IBKR智能传递在做出传递决定时，会把交易费因素（包括专业和非专业客户费用的差距）考虑在内。

更多额外信息，请查看以下链接：

CBOE监管通告RG16-064

ISE 2014 RIC and 2016 RIC

NYSE AMEX 10-29

Background

Effective October 3, 2016, securities exchanges registered with the SEC will operate a Tick Size Pilot Program ("Pilot") intended to determine what impact, if any, widening of the minimum price change (i.e., tick size) will have on the trading, liquidity, and market quality of small cap stocks.  The Pilot will last for 2 years and it will include approximately 1,200 securities having a market capitalization of $3 billion or less, average daily trading volume of 1 million shares or less, and a volume weighted average price of at least $2.00.

For purposes of the Pilot, these securities will be organized into groups that will determine a minimum tick size for both quote display and trading purposes. For example, Test Group 1 will consist of securities to be quoted in $0.05 increments and traded in $0.01 increments and Test Group 2 will include securities both quoted and traded in $0.05 increments.  Test Group 3 will include also include securities both quoted and traded in $0.05 increments, but subject to Trade-at rules (more fully explained in the Rule). In addition, there will be a Control Group of securities that will continue to be quoted and traded in increments of $0.01. Details as to the Pilot and securities groupings are available on the FINRA website.

Impact to IB Account Holders 

In order to comply with the SEC Rules associated with this Pilot, IB will change the way that it accepts orders in stocks included in the Pilot.  Specifically, starting October 3, 2016 and in accordance with the phase-in schedule, IB will reject the following orders associated with Pilot Securities assigned to Test Groups:

• Limit orders having an explicit limit that is not entered in an increment of $0.05;
• Stop or Stop Limit orders having an explicit limit that is not entered in an increment of $0.05; and
   
• Orders having a price offset that is not entered in an increment of $0.05.  Note that this does not apply to offsets which are percentage based and which therefore allow IB to calculate the permissible nickel increment

 Clients submitting orders via the trading platform that are subject to rejection will receive the following pop-up message:

 The following order types will continue to be accepted for Pilot Program Securities:

• Market orders;
• Benchmark orders having no impermissible offsets (e.g., VWAP, TVWAP);
• Pegged orders having no impermissible offsets ;
• Retail Price Improvement Orders routed to the NASDAQ-BX and NYSE as follows:
  - Test Group 1 in .001

      - Test Group 2 and 3 in .005

Other Items of Note

• GTC limit and stop orders entered prior to the start of the Pilot will be adjusted as allowed (e.g., a buy limit order at $5.01 will be adjusted to $5.00 and a sell limit at $5.01 adjusted to $5.05).
• Clients generating orders via third-party software (e.g., signal provider), order management system, computer to computer interfaces (CTCI) or through the API, should contact their vendor or review their systems to ensure that all systems recognize the Pilot restrictions.
• Incoming orders to IB that are marked with TSP exception codes from other Broker Dealers will not be acted upon by IB. For example, IB will not accept incoming orders marked with the Retail Investor Order or Trade-At ISO exception codes.
• The SEC order associated with this Pilot is available via the following link: https://www.sec.gov/rules/sro/nms/2015/34-74892-exa.pdf
• For a list of Pilot Program related FAQs, please see KB2750

Please note that the contents of this article are subject to revision as further regulatory guidance or changes to the Pilot Program are issued.

Introduction

The following article is intended to provide an overview of U.S. Securities and Exchange Commission (“SEC”) Sections 13(d) and 13(g) Filing Requirements. The overview is general in nature, and readers are encouraged to review the specific regulations and/or consult with a compliance professional to determine the applicability to their particular situation.

Background on Schedules 13D and 13G

These rules apply to anyone who “beneficially owns” Section 12 securities as defined in the Securities Exchange Act of 1934 (the "Act"). This generally includes shares you own or manage. Specifically, you are deemed to “beneficially own” for purposes of Section 13(d) a security if you have, either directly or indirectly:
• The power to vote or direct the voting of a security;
• The power to dispose or direct the disposition of a security; or
• The right to acquire “beneficial ownership” of such security within 60 days through the exercise of an option or warrant or the exercise of a conversion right in a convertible security.

To determine whether you “beneficially own” more than 5% of a class of equity security, measure the amount you are deemed to “beneficially own” against the total amount of outstanding securities of that class. You may rely upon the issuer’s most recent quarterly or annual report (10-Q or 10-K) filed with the SEC and any current report (Form 8-K) filed later in identifying the amount of outstanding shares. You must include any equity securities you may obtain within 60 days through the conversion or exercise of options, warrants or other as outstanding shares in this calculation. But you do not need to include similar non-exercised or converted shares held by anyone else.
 

What filings you must make

Your initial Schedule 13D filing must be made within 10 days of the trade date on which you first exceeded the 5% threshold. Disclosures in Schedule 13D must be current through the date of filing.

Schedule 13D filings must also be promptly amended, within two business days, to reflect any material changes. This includes the acquisition or disposition of 1% or more of the reported securities or significant changes in any intent you may have to control the issuer.

Some traders may be able to file an abbreviated filing—called a 13G—instead of a 13D. This option is available to passive investors owning less than 20% of the security or exempt investors owning more than 5% of an issuer’s shares before the issuer’s registration of the class of securities. In addition, SEC or state-registered advisors can only file a Schedule 13G if they have acquired the relevant securities in the ordinary course of the firm’s advisory business and not for the purpose of or with the effect of influencing control of the issuer. Also, the advisor must have notified any discretionary account owner on whose behalf the advisor holds more than 5% of relevant equity securities of his potential reporting obligation. Very specific filing thresholds and deadlines apply to initial and amended Schedule 13G filings.
 

Important Notes

• Please keep in mind that your clients and your firm’s direct and indirect control persons (which may include partners, shareholders and parent companies) may have their own independent reporting obligations.

• You should independently review your Schedule 13D and 13G filing obligations. There are many factual determinations that may impact whether you must make a filing or amend a prior filing, which Schedule you must file (or amend), and when you must make your filing.

• Interactive Brokers will provide you, on a best efforts basis, with notices only when you cross certain thresholds (5%, 10%, 20%) or a significant change in the percentage of shares you manage occurs. There may be other situations that give rise to the need to file a Schedule 13D or 13G for which you will not receive an alert from Interactive Brokers.

• Interactive Brokers will only send you one initial filing alert for each threshold you cross. We will only resend you an initial filing alert if you cross one of the three thresholds (5%, 10% or 20%) that is higher than the threshold you have crossed before. (i.e., we will not tell you if you crossed the 5% threshold if you have already crossed the 10% threshold.) Therefore, please continually monitor your positions and make the appropriate filing(s) after you receive an initial filing or amendment notice.

• You should monitor holdings of specific classes of issuer equity securities in the accounts you manage to ensure compliance with your Schedule 13D or 13G filing and amendment obligations.

• Notices do not cover (nor will they take into account) certain securities not commonly traded through Interactive Brokers, namely equities in:

a. an insurance company that would have to be registered except for the exemption from registration in Section 12(g)(2)(G) of the Act;

b. a closed-end investment company registered under the Investment Company Act of 1940; or

c. a Native Corporation pursuant to Section 1639c(d)(6) of title 43.

You should therefore separately account for and analyze any holdings of such equity securities you may have to comply with Section 13(d) of the Act.

• Alerts sent are based exclusively on the beneficial ownership of relevant securities of the specific advisor identified. The alerts will not account for any group aggregation rules that may apply when two or more persons agree to act together for the purpose of acquiring, holding, voting or disposing of the equity securities of an issuer.

• Alerts sent relate solely to holdings in accounts maintained at Interactive Brokers and not any accounts maintained elsewhere. But you should take any accounts you maintain elsewhere into consideration when determining whether you must file or amend a Schedule 13D or 13G and what information to include in those schedules.

• Alerts sent will not take into consideration your Schedule 13D or 13G filing obligations arising prior to the date of Interactive Broker's implementation of this alert program.

• The data we receive about US Micro-Cap securities—generally OTC listed stocks, as well as Nasdaq or NYSE American stocks with a market cap of less than $300MM that trade under $5 per share--from our data provider is not consistently reliable so we have removed those securities from this program. As a result, you will not receive Schedule 13D/13G alerts when you come close to crossing or cross thresholds triggering filing obligations regarding U.S. Micro-Cap securities. You should separately review your holdings in US Micro-Cap stocks to determine your related filing obligations for those holdings.
 

For Additional Information

For more information on Schedules 13D and 13G, please visit the SEC website at:

http://www.sec.gov/answers/sched13.htm  and 

https://www.sec.gov/divisions/corpfin/guidance/reg13d-interp.htm
 

Overview