--- title: "Exchange Operator 13Fs: NYSE Parent (ICE), CME, Cboe, Nasdaq" type: learn slug: exchange-operator-13f-ice-cme-cboe-nasdaq-decoder canonical_url: https://13finsight.com/learn/exchange-operator-13f-ice-cme-cboe-nasdaq-decoder published_at: 2026-05-15T08:50:51.183Z updated_at: 2026-05-15T08:50:54.953Z author: Sarah Mitchell author_title: Education Editor author_url: https://13finsight.com/authors/sarah-mitchell word_count: 521 locale: en source: 13F Insight --- # Exchange Operator 13Fs: NYSE Parent (ICE), CME, Cboe, Nasdaq > ICE, CME Group, Cboe Global Markets, and Nasdaq operate the regulated US exchange infrastructure. Their 13F holders include concentrated quality-discipline managers like Harris Associates, PineStone, and BLS Capital. Reading exchange-operator 13Fs requires understanding regulated-monopoly economics. US exchange operators run regulated-monopoly businesses with structurally durable economics: high operating margins, low capex requirements, regulated competitive moats, and pricing power on trading-volume fees plus market-data subscriptions. Four major US-listed exchange operators dominate the category: Intercontinental Exchange (ICE) — parent of NYSE plus derivatives clearinghouses; CME Group (CME) — dominant US futures-and-options exchange operator; Cboe Global Markets (CBOE); and Nasdaq Inc. (NDAQ). Their 13F holder books carry distinctive concentrated active-manager positions because the franchise economics fit quality-and-value-discipline factor frameworks especially well.The exchange-operator business modelFour characteristics make exchange operators distinctive:Regulated-monopoly economics. Exchange-operator licenses are heavily regulated by SEC and CFTC. New-entrant barriers are structural; competitive moats are durable.Capital-light operating model. Operating margins above 55% with low capital expenditure requirements. Most revenue flows to free cash flow.Pricing power on trading volume. Exchange operators capture per-transaction fees on trading volume that scales with market growth. The trading-volume revenue base compounds across cycles.Market data subscription revenue. Real-time market data, indexes, and analytics subscriptions provide recurring revenue independent of trading-volume volatility.Combined, these characteristics produce a quality-and-compounder business profile that quality-discipline factor frameworks prize highly.The institutional positioning patternsPattern 1: Concentrated quality-discipline managersQuality-and-value-discipline managers consistently overweight exchange operators:Harris Associates holds ICE at 3.19% portfolio (Oakmark Funds value-discipline overweight).PineStone Asset Management holds CME at 5.39% portfolio.BLS Capital holds Moody's at 7.70% and S&P Global at 12.75% — adjacent financial-data infrastructure.Gardner Russo & Quinn holds Mastercard at 9.15% — adjacent payments-network economics.Pattern 2: International active overweightsNon-US-domiciled active managers also overweight exchange operators because the regulated-monopoly economics translate across global mandate frameworks.Pattern 3: Limited Berkshire participationBuffett has not built concentrated positions in US exchange operators despite the quality-compounder characteristics. Berkshire's preference for closed-loop network economics (Amex over Visa/Mastercard) extends to selectively avoiding the exchange-operator category.How to identify exchange-operator concentrated positionsFive fingerprints:Filer is a concentrated quality-discipline manager. Harris Associates (Oakmark), Gardner Russo & Quinn, PineStone, BLS Capital, similar firms.Position weight above 2.5% portfolio. Exchange operators rarely appear at meaningful weights in diversified active mandates; concentrated quality positions stand out.Multi-quarter holding pattern. Quality-discipline managers hold exchange operators across multiple price cycles without forced trimming.Cross-fund consensus. When multiple international quality managers hold the same exchange operator at concentrated weights, the consensus is structural.Adjacent financial-data positions. Exchange-operator holders typically also hold financial-data names (Moody's, S&P Global, MSCI) and payments networks (Mastercard, Visa) — the broader 'tax-and-toll' infrastructure cluster.The four major US-listed exchange operatorsFilerMarketsDistinctive HolderIntercontinental Exchange (ICE)NYSE, derivatives, mortgage techHarris Associates at 3.19%CME Group (CME)Futures, options, FXPineStone at 5.39%Cboe Global Markets (CBOE)Options, ETFs, digital assetsVarious quality managersNasdaq Inc. (NDAQ)Equity listings, market data, trading techVarious quality managersWhat to trackTrading volume trends. Equity-and-derivatives trading volumes drive exchange-operator revenue. Watch quarterly disclosures from each exchange.Market data subscription pricing. Exchange operators have pricing power on real-time market data subscriptions. Annual price increases compound revenue.Regulatory environment changes. Major SEC or CFTC rule changes affecting market structure (Credit Card Competition Act analog, payment-for-order-flow rules, etc.) can materially shift exchange-operator economics.Cybersecurity risk. Exchange operators face elevated cyber threats; any successful attack would materially affect institutional positioning.For real-time tracking of exchange-operator 13F activity, see the institutional signals feed. For related reading techniques on financial-data and payments-network 13F positioning, see our Visa-Mastercard duopoly decoder. ## FAQ ### What makes exchange operators a distinctive 13F category? Exchange operators run regulated-monopoly businesses with four characteristics: (1) regulated-monopoly economics with high new-entrant barriers from SEC and CFTC licensing; (2) capital-light operating model with margins above 55% and low capex; (3) pricing power on per-transaction trading-volume fees that scales with market growth; (4) market data subscription revenue providing recurring economics. Combined, produces quality-compounder business profile. ### Who are the major US-listed exchange operators? Four major US-listed exchange operators dominate the category: Intercontinental Exchange (ICE) — parent of NYSE plus derivatives clearinghouses plus mortgage technology; CME Group (CME) — dominant US futures-and-options exchange operator; Cboe Global Markets (CBOE) — options and ETF trading plus digital assets; and Nasdaq Inc. (NDAQ) — equity listings, market data, and trading technology platforms. ### Which active managers overweight exchange operators? Concentrated quality-discipline managers consistently overweight exchange operators: Harris Associates (Oakmark Funds) holds ICE at 3.19% portfolio; PineStone Asset Management holds CME at 5.39%; BLS Capital holds adjacent financial-data names (S&P Global at 12.75%, Moody's at 7.70%); Gardner Russo & Quinn holds Mastercard at 9.15%. International active managers also frequently overweight because regulated-monopoly economics translate across global mandate frameworks. ### Why doesn't Berkshire hold exchange operators? Warren Buffett has not built concentrated positions in US exchange operators despite their quality-compounder characteristics. Berkshire preference for closed-loop network economics (American Express vertical-integration over Visa-Mastercard four-party network) extends to selective avoidance of exchange-operator category. Pattern of preferring vertically-integrated networks over multi-party regulated-monopoly economics is consistent across Buffett history. ### What signals exchange-operator institutional consensus? Five fingerprints: (1) concentrated quality-discipline manager holds at 2.5%+ portfolio weight; (2) position is held across multiple quarterly cycles without trimming; (3) cross-fund consensus where multiple international quality managers hold the same exchange operator; (4) adjacent financial-data and payments-network positions (the broader 'tax-and-toll' cluster); (5) low position turnover indicating multi-year holding philosophy. Combined signals point to structural quality conviction. ### What are the main risks to exchange-operator economics? Three primary risks: (1) regulatory rule changes — major SEC or CFTC rule changes (payment-for-order-flow, market-structure modifications, credit-card-competition-act-style legislation) can materially shift exchange-operator economics; (2) trading-volume cyclicality — equity-and-derivatives volumes are cyclical with broader macro cycles; (3) cybersecurity threats — exchange operators sit in highest-stakes cyber threat envelope. --- Source: 13F Insight — https://13finsight.com/learn/exchange-operator-13f-ice-cme-cboe-nasdaq-decoder Author: Sarah Mitchell — https://13finsight.com/authors/sarah-mitchell Last updated: 2026-05-15T08:50:54.953Z