Since July 2023, Cboe BZX has filed more than a dozen times to raise its 10 Gigabit physical port fee from $7,500 to $8,500 per month — a 13.3% increase. Each time, the SEC has either suspended the filing, instituted proceedings, or forced a withdrawal. The fee remains at $7,500, exactly where it was set in June 2018. This study traces the full port fee timeline from 2017 and examines why BZX's pricing power over its own connectivity fee schedule has, for two years, effectively been overridden by the Commission.
As of May 2026, Cboe BZX's 10Gb physical port fee remains at $7,500/month — unchanged since June 2018. The Exchange has filed to raise it to $8,500 at least 13 times across BZX Equities and BZX Options platforms since July 2023. The SEC has suspended or forced withdrawal of every attempt under Section 19(b)(3)(C) of the Securities Exchange Act.
The most recent filing in our dataset (SR-CboeBZX-2025-100, August 2026) shows the same unchanged language: "currently assesses $7,500 per 10 Gb circuit — proposes to increase to $8,500."
A physical port is the hardware-level connection between a trading firm's co-located equipment and an exchange's matching engine. When a broker-dealer, HFT firm, or market maker co-locates servers at NYSE's Mahwah data center, Cboe's Aurora/Secaucus data centers, or Nasdaq's Carteret facility, they connect to the exchange's trading system through physical ports — typically 1 Gigabit (Gb) or 10 Gb fiber circuits, with 100 Gb options now available at most venues.
The monthly fee for a physical port is one of the most direct and non-negotiable costs in market data and connectivity budgets. Unlike transaction fees (which are rebatable) or market data fees (which can be shared across users), each port connection requires a separate monthly payment regardless of trading volume. A firm with connections to six Cboe exchanges pays six separate port fees per month.
Any entity that co-locates equipment at an exchange data center pays physical port fees: broker-dealers, HFT firms, institutional market makers, clearing firms, and SaaS platforms offering co-located infrastructure. A large market-making firm maintaining primary and backup connections across Cboe's six equity exchanges might pay $45,000–$90,000/month in port fees to Cboe alone, depending on circuit speed.
The Cboe BZX physical port fee history is unusually well-documented in the Federal Register because Cboe files separately for each exchange and each platform (equities vs. options), producing a detailed paper trail of every proposed change.
Dashed line = proposed $8,500 (all proposals blocked by SEC since July 2023). Solid line = in-effect fee confirmed from Federal Register filings.
Under Section 19(b)(3)(C) of the Securities Exchange Act, the SEC has 60 days to review an immediately-effective filing and may temporarily suspend it if it "appears to be inconsistent with the requirements" of the Act. The SEC then has 240 days to approve or disapprove, after which the rule takes effect if no action is taken.
The SEC's 2023 order suspending the BZX port fee increase cited the standard Section 6(b)(4) and 6(b)(5) requirements: that exchange fees be "reasonable," "equitably allocated," "not designed to permit unfair discrimination," and that they do not "impose any burden on competition not necessary or appropriate in furtherance of the purposes" of the Act.
The specific concern with port fees — particularly the frequency with which the SEC has intervened in port and colocation fee increases — stems from a 2019-era policy shift under which the Commission began scrutinizing the "reasonableness" of exchange infrastructure fees more aggressively. Exchanges have historically argued that because co-location is entirely optional, port fees cannot be coercive. The SEC has pushed back that the practical necessity of co-location for competitive market-making makes "optional" a theoretical rather than real characterization.
In January 2021, MIAX filed SR-MIAX-2021-02 to raise its 10Gb ultra-low latency (ULL) fiber connection fee from $9,300 to $10,000 per month — a 7.5% increase on a fee already 24% higher than BZX's current 10Gb rate. The SEC did not suspend this filing. MIAX's increase took effect immediately.
The asymmetry is notable: the SEC allowed a $700 increase on a $9,300 base (7.5%) at MIAX but has blocked a $1,000 increase on a $7,500 base (13.3%) at Cboe BZX for over two years. Institutional differences — Cboe BZX's scale, subscriber concentration, and market share in equities — likely factor into the SEC's calculus.
The SEC has not published a formal disapproval order for any of the BZX port fee filings — the proceedings remain open. As long as proceedings are active and BZX keeps withdrawing and refiling, the fee effectively stays frozen. This creates an unusual regulatory dynamic: the Exchange is repeatedly exercising its right to file, and the SEC is repeatedly exercising its right to suspend, with no final resolution.
For a firm maintaining co-located connections to all six Cboe equity exchanges (BZX, BYX, EDGA, EDGX, C2, CBOE) via 10 Gb ports at both primary and backup data centers, the blocked increase represents a material ongoing saving:
| Scenario | Ports | At $7,500/mo | At $8,500/mo (proposed) | Monthly Saving | Annual Saving |
|---|---|---|---|---|---|
| Single BZX 10Gb port | 1 | $7,500 | $8,500 | $1,000 | $12,000 |
| BZX Equities + Options (2 ports) | 2 | $15,000 | $17,000 | $2,000 | $24,000 |
| All 6 Cboe exchanges, primary site | 6 | $45,000 | $51,000 | $6,000 | $72,000 |
| All 6 Cboe exchanges, primary + backup | 12 | $90,000 | $102,000 | $12,000 | $144,000 |
| Large market maker (est. 20 total ports) | 20 | $150,000 | $170,000 | $20,000 | $240,000 |
The savings are real but not the primary driver of the industry's resistance to port fee increases. More significant is the precedent: if BZX successfully raises its 10 Gb port fee, other Cboe venues (BYX, EDGA, EDGX, C2, CBOE) and competitor exchanges would likely file similar increases. The compound effect across all exchanges and port types would be far larger than any single-venue change.
Data source: Federal Register API (federalregister.gov/api/v1), HTML body text fetched for 73 port-fee filings from NYSE, Cboe BZX, and Nasdaq (2017–2026). This is Study 3 of 3 in our 19b-4 analysis series.
Fee extraction: Exact dollar amounts extracted directly from filing body text via keyword search within Federal Register HTML documents. All fee amounts cited in this study are verbatim quotes from the relevant filing.
Cboe BZX timeline: Based on confirmed text from SR-BatsBZX-2017-75 (Nov 2017), SR-CboeBZX-2018-037 (Jun 2018), SR-CboeBZX-2023-046 (Jul 2023), and SR-CboeBZX-2025-100 (Aug 2025). The 2017 post-change fee of $7,000 is inferred from the 2018 filing's "currently assesses $7,000" background statement.
MIAX comparison: Based on SR-MIAX-2021-02 (Jan 2021) which states explicitly the increase from $9,300 to $10,000 for 10Gb ULL connections.
NYSE note: NYSE's connectivity fee structure differs from Cboe's — NYSE uses a "Connectivity Fee Schedule" with products including 10Gb dedicated circuits, logical ports, and wireless connections, which are not directly comparable to Cboe's physical port fees. NYSE connectivity fee analysis requires a separate methodology and is not included here.
Limitations: "Blocked" in this study means the SEC temporarily suspended the filing under Section 19(b)(3)(C) and/or BZX withdrew the filing before the 240-day period expired. It does not mean the SEC formally disapproved the change — proceedings remain open as of the study date. The exact count of individual filings vs. withdrawals may differ slightly based on how refilings and amendments are counted.