# CBOE FIXED INCOME MARKETS, LLC X-17A-5 (2025-02-26) — Broker-dealer annual report

- Company: CBOE FIXED INCOME MARKETS, LLC
- Form: X-17A-5
- Filed: 2025-02-26
- Period: 2024-12-31
- Accession: 0001871012-25-000001
- CIK: 1871012
- File #: 8-70752
- Type: Broker-dealer
- Material weakness: No
- Auditor: KPMG LLP
- Auditor location: Kansas City, MO
- Contact: Casie Harris
- Phone: 913-815-7113
- Email: charris@cboe.com
- Website: cboe.com
- Signed by: Casie Harris (Controller)

Original filing: https://www.sec.gov/Archives/edgar/data/1871012/000187101225000001/2024_SEC_CFIM_Public.pdf

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

> ANNUAL REPORTS FORM X-17A-5 PART III

| OMB APPROVAL              |
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| OMB Number: 3235-0123     |
| Explres: Nov. 30, 2026    |
| Estimated average burden  |
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| SEC FILE NUMBER |  |
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| 8-70752         |  |

FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

filing for the period beginning 01/01/24

MM/DD/YY

MM/DD/YY

12/31/2024

A. REGISTRANT IDENTIFICATION

# NAME OF FIRM: Cboe Fixed Income Markets, LLC

TYPE OF REGISTRANT (check all applicable boxes):

₪ Broker-dealer □ Check here if respondent is also an OTC derivatives dealer

AND ENDING

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)

## 17 State Street, 31st Floor

|                                                                                       |  | (No. and Street)                                           |                  |            |
|---------------------------------------------------------------------------------------|--|------------------------------------------------------------|------------------|------------|
| New York                                                                              |  | NY                                                         |                  | 10004      |
| (City)                                                                                |  | (State)                                                    |                  | (Zip Code) |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                          |  |                                                            |                  |            |
| (913) 815 - 7113<br>Casie Harris                                                      |  |                                                            | charris@cboe.com |            |
| (Name)                                                                                |  | (Area Code - Telephone Number)                             | (Email Address)  |            |
|                                                                                       |  | B. ACCOUNTANT IDENTIFICATION                               |                  |            |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>KPMG LLP |  |                                                            |                  |            |
|                                                                                       |  | (Name - if individual, state last, first, and middle name) |                  |            |
| 1000 Walnut, Suite 1100                                                               |  | Kansas City                                                | MO               | 64106      |
| (Address)                                                                             |  | (City)                                                     | (State)          | (Zip Code) |
| 10/20/2003                                                                            |  |                                                            | 185              |            |

| (Name - if individual, state last, first, and middle name) |                       |         |                                            |  |
|------------------------------------------------------------|-----------------------|---------|--------------------------------------------|--|
| 1000 Walnut, Suite 1100                                    | Kansas City           | MO      | 64106                                      |  |
| (Address)                                                  | (City)                | (State) | (Zip Code)                                 |  |
| 10/20/2003                                                 |                       | 185     |                                            |  |
| (Date of Registration with PCAOB)(if applicable)           |                       |         | (PCAOB Registration Number, if applicable) |  |
|                                                            | FOR OFFICIAL USE ONLY |         |                                            |  |
|                                                            |                       |         |                                            |  |

\* Claims for exemption from the requirement that the annual reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable.

Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valld OMB control number.

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### OATH OR AFFIRMATION

| Casie Harris                                                              | swear (or affirm) that, to the best of my knowledge and belief, the                                                                 |
|---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| tinancial report pertaining to the firm of Cboe Fixed Income Markets, LLC | as of                                                                                                                               |
| 12/31                                                                     | 2 024 is true and correct. I further swear (or affirm) that neither the company nor any                                             |
|                                                                           | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely |
| as that of a customer.                                                    |                                                                                                                                     |
|                                                                           |                                                                                                                                     |
|                                                                           | BRIAN SEANTLE<br>Signature:<br>Notary Poblic State of Kansa.<br>1. Harry                                                            |
|                                                                           | My Appoint cont Expires                                                                                                             |
|                                                                           | 3 29/28<br>Title:                                                                                                                   |
|                                                                           | Cantrallar                                                                                                                          |

Notary Public

### This filing\*\* contains (check all applicable boxes):

- = (a) Statement of financial condition.
- (b) Notes to consolidated statement of financial condition.
- □ (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- 0 (d) Statement of cash flows.
- □ (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- [ (f) Statement of changes in liabilities subordinated to claims of creditors.
- □ (g) Notes to consolidated financial statements.
- □ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- [ ] (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- □ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- □ (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- □ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- □ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- □ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- □ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- {q} Oath or affirmation in accordance with 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- □ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- □ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- (t) Independent public accountant's report based on an examination of the statement of financial condition.
- □ (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- □ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- □ (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- □ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- □ (z) Other:

<sup>\*\*</sup>To request confidential treatment of certain portions of this filing, see 17 CFR 240.17o-5(e)(3) or 17 CFR 240.180-7(d)(2), as applicable.

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## Cboe Fixed Income Markets, LLC

Financial Statement

(With Report of Independent Registered Public Accounting Firm Thereon)

As of December 31, 2024

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![](_page_3_Picture_0.jpeg)

KPMG LLP Suite 1100 1000 Walnut Street Kansas City, MO 64106-2162

## Report of Independent Registered Public Accounting Firm

To the Member of Cboe Fixed Income Markets, LLC:

### Opinion on the Financial Statement

We have audited the accompanying statement of financial condition of Cboe Fixed Income Markets, LLC (the Company) as of December 31, 2024, and the related notes (collectively, the financial statement). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2024, in conformity with U.S. generally accepted accounting principles.

### Basis for Opinion

This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on this financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion.

![](_page_3_Picture_9.jpeg)

We have served as the Company's auditor since 2022.

Kansas City, Missouri February 26, 2025

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### Cboe Fixed Income Markets, LLC

Statement of Financial Condition December 31, 2024

### Assets

| Cash                                   | ക്ക  | 4,368,561 |
|----------------------------------------|------|-----------|
| Deposits with clearing counterparty    |      | 250,000   |
| Other assets                           |      | 15,226    |
| Total assets                           | ತಿ   | 4,633,787 |
| Liabilities and Member's Equity        |      |           |
| Liabilities:                           |      |           |
| Accounts payable and accrued expenses  | ക്ക  | 7,636     |
| Payable to affiliate, net              |      | 165,965   |
| Total liabilities                      |      | 173,601   |
| Commitments and contingencies (note 8) |      |           |
| Member's equity:                       |      |           |
| Total member's equity                  |      | 4,460,186 |
| Total liabilities and member's equity  | ಕ್ಕಾ | 4,633,787 |
|                                        |      |           |

See accompanying notes to financial statement.

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### (1) Nature of Business

Cboe Fixed Income Markets, LLC ("the Company") was formed as a Delaware Limited Liability Company on May 25, 2021. On July 6, 2022, the Company registered as a broker-dealer with the Securities and Exchange Commission ("SEC") and a member of the Financial Industry Regulatory Authority ("FINRA").

The Company is an indirect, wholly-owned subsidiary of Cboe Global Markets, Inc. ("the primary business activity of the Company is to operate a U.S. Treasury securities trading system for its participants, each of which must be a broker-dealer. The Company operates under a (k)(2)(ii) exemption from Rule 15c3-3 and clears all customer transactions through an unaffiliated broker-dealer on a fully-disclosed basis.

### (2) Summary of Significant Accounting Policies

#### Principles of Accounting (a)

The financial statement is presented in conformity with generally accepted accounting principles in the United States ("GAAP") as established by the Financial Accounting Standards Board ("FASB"). References to GAAP in these footnotes are to the FASB Accounting Standards Codification ("ASC" or "Codification").

#### Use of Estimates (b)

The preparation of the financial statement in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities as well as disclosure of the amounts of contingent assets and liabilities at the financial statement. Actual results could differ significantly from those estimates.

#### (c) Cash

The Company maintains cash at a financial institution that, at times, may be in excess of the federal insurance limits.

### (d) Restricted Cash

The Company maintains a cash balance deposited with the clearing counterparty, Mirae Asset Securities (USA) Inc. ("Mirae"), used for the clearing of customer transactions of the Company in accordance with the Clearing Agreement between the Company and Mirae. The Company is required to maintain a minimum clearing deposit balance of \$250,000 with Mirae and is required to maintain minimum net capital at or above 120% of the net capital requirement imposed by FINRA.

#### (e) Equipment, net

Equipment, net is stated at cost less accumulated depreciation. The equipment consists of network, servers, and storage equipment.

#### (f) Other assets

Other assets consist of prepaid expenses.

#### (g) Income Taxes

The Company is included in the consolidated federal income tax return filed by the Parent. As the Company is a legal entity that is not subject to tax, there is no allocation of the Parent's income taxes in the Company's financial statement.

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### (3) Fair value measurements

Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date and sets out a fair value hierarchy. The fair value hierarchy gives the highest prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). Inputs are broadly defined as assumptions market participants would use in pricing an asset or liability. The three levels of the fair value hierarchy are described below:

Level 1: Unadjusted quoted prices in active markets for identical assets or liabilities that the reporting entity has the ability to access at the measurement date.

Level 2: Inputs other than quoted prices within Level 1 that are observable for the asset or liability, either directly or indirectly; fair value is determined through the use of models or other valuation methodologies. A significant adjustment to a Level 2 input could result in the Level 2 measurement becoming a Level 3 measurement.

Level 3: Inputs are unobservable for the asset or liability and include situations where there is little, if any, market activity for the asset or liability. The inputs into the determination of fair value are based upon the best information in the circumstances and may require significant management judgment or estimation.

The fair value of the Company's financial instruments, including accounts payable and accrued expenses, approximates the carrying value due to their short-term nature.

### (4) Net Capital Requirements

The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1), which requires the maintenance of minimum net capital. The SEC's requirement also provides that equity capital may not be withdrawn or cash dividends paid if certain minimum net capital requirements are not met. The Company computes its net capital requirements under the basic method provided for in SEC Rule 15c3-1. SEC Rule 15c3-1 requires the Company to maintain net capital equal to the greater of 6-2/3% of aggregate indebtedness items, as defined, or \$5,000. At December 31, 2024, the Company had net capital of \$4,444,960, which was \$4,433,387 in excess of its required net capital of \$11,573. The ratio of aggregate indebtedness to net capital was 0.04 to 1.

### (5) Equipment, net

The following table represents the Company's equipment, net as of December 31, 2024:

| Equipment                     | 582.632   |
|-------------------------------|-----------|
| Less accumulated depreciation | (582.632) |
| Equipment, net                |           |

### (6) Related Party Transactions

The Company is a party to a Master Intercompany Services & License Agreement (the "Agreement") with the Parent. Pursuant to this Agreement, certain affiliates of the Parent provide shared services to the Company such as accounting and payroll. The payable to affiliate was \$165,965 as of December 31, 2024. The Company settles all activity with the other affiliates through the Parent annually or as needed.

### (7) Segment Reporting

The Company operates as a single reportable segment as its sole function is to operate a U.S. Treasury securities trading system for its participants. The Company's chief operating decision maker ("CODM") is the President of the Company. The CODM assesses capital adequacy in order to make operational decisions based on excess net capital. See Note 4 ("Net Capital Requirements") for more information.

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### Cboe Fixed Income Markets, LLC Notes to Financial Statement As of December 31, 2024

### (8) Commitments and Contingencies

As a SEC registered broker-dealer and member of FINRA, the Company is subject to examinations and inspections by the SEC and FINRA. Additionally, from time to time the Company may be involved in various legal proceedings arising in the ordinary course of business. The Company does not believe that the outcome of any of these examinations, inspections, or other legal proceedings will have a material impact on the financial statement; however, litigation is subject to many uncertainties, and the outcome of individual litigated matters is not predictable with assurance.

The Company may be exposed to counterparty credit risk in the Company's fully disclosed clearing broker, Mirae, fails to perform any of its contractual obligations to the Company. Mirae clears all U.S. government securities transactions executed on the Company's platform. Mirae, a SEC-registered brokerdealer and a member of DTCC's Fixed Income Clearing Corporation ("FICC") Government Securities Division ("GSD"), acts as the Company's fully disclosed counterparty to both participants (buyer and seller) on any matched orders on the system (resulting in two offsetting trades for Mirae). All participants of the platform are required to be registered broker-dealers and members of FICC's GSD. The Company believes that such potential counterparty credit risk exposure is remote; however, such risk is possible.

### (9) Subsequent Events

The Company performed an evaluation of events that have occurred subsequent to December 31, 2024, through February 26, 2025, which is the financial statement was available to be issued. There have been no subsequent events that have occurred during such period that would require disclosure in the financial statement or would be required to be recognized in the financial statement as of December 31, 2024.


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
