On 20 August 2025, the United States Securities and Exchange Commission published a notice for proposed changes by BOX Exchange LLC filing that is effective immediately. The proposal amends BOX Rule 3120 to raise position and exercise limits for options on GBTC, BITB, and BTC. The change removes these products from IM 3120 2 so limits are set under Rule 3120 and Rule 3140. Limits may rise from 25,000 contracts to levels determined by trading activity. The filing cites prior United States SEC approvals on other venues and seeks comment under File No. SR BOX 2025 23. The United States SEC also waived the thirty day operative delay and designated the rule operative on filing.
The filing is titled “Self Regulatory Organizations; BOX Exchange LLC; Notice of Filing and Immediate Effectiveness of Proposed Change to Amend BOX Rule 3120 to Increase the Position and Exercise Limits for the Grayscale Bitcoin Mini Trust ETF, the Bitwise Bitcoin ETF, and the Grayscale Bitcoin Trust ETF.” The subject is the increase of position and exercise limits for options on BTC, BITB, and GBTC.
United States SEC action and effectiveness
While allowing the amendment the US SEC gave its reason as follows:
“The Exchange has filed the proposed rule change pursuant to Section 19(b)(3)(A)(iii) of the Act58 and Rule 19b-4(f)(6) thereunder.59 Because the proposed rule change does not: (i) significantly affect the protection of investors or the public interest; (ii) impose any significant burden on competition; and (iii) become operative prior to 30 days from the date on which it was filed, or such shorter time as the Commission may designate, if consistent with the protection of investors and the public interest, the proposed rule change has become effective pursuant to Section 19(b)(3)(A) of the Act and Rule 19b-4(f)(6)(iii) thereunder.”
The filing states that the proposed change became effective on submission under Section 19(b)(3)(A) of United States Securities Exchange Act and Rule 19b 4(f)(6). The United States SEC waived the thirty day operative delay and designated the proposal operative upon filing. The notice explains that the action raises no novel legal issues and provides another venue with limits that may exceed 25,000 contracts.
What changes for BOX options
BOX proposes to delete the fixed 25,000 contract cap for these Bitcoin ETF options by removing them from IM 3120 2. Position limits will instead follow Rule 3120, which ties limits to recent six month trading volume and shares outstanding. Exercise limits will mirror position limits under Rule 3140. The effect is to align BTC, BITB, and GBTC options with the standard equity option framework on BOX.
Comparative references and rationale
The filing is a competitive response to approvals on NYSE Arca and prior analysis by other exchanges. It notes that these ETFs have trading volumes that qualify for higher tiers under exchange rules. The filing explains that higher limits can support hedging, improve liquidity, and help listed markets compete with over the counter activity while preserving investor protection.
Surveillance, reporting, and safeguards
Existing surveillance and reporting programs remain in force. Large Option Position Reporting continues to apply. Market Makers are exempt from customer reporting but remain subject to information requests. BOX describes coordination with FINRA and intermarket surveillance groups. The notice stresses that procedures exist to detect unusual activity and potential manipulation.
Comment process and file details
Comments should reference File No. SR BOX 2025 23. Submissions can be made through the United States SEC rule comment portal or by email to rule comments@sec.gov. Copies will be available at the exchange and on the United States SEC website. The United States SEC may suspend the rule within sixty days and institute proceedings if required in the public interest.
(Source: https://www.sec.gov/files/rules/sro/box/2025/34-103748.pdf)
