Cboe Global Markets, Inc. (CBOE) Earnings Call Transcript & Summary
November 10, 2020
Earnings Call Speaker Segments
Michael Carrier
analystI'm Mike Carrier. I cover the brokers, asset managers and exchanges at BofA, and hope you're all doing well. Next up, we have Cboe Global Markets. And with us today, we have Ed Tilly, Interim President and CEO; and Brian Schell, Chief Financial Officer and Treasurer. Ed and Brian, thanks for being with us today.
Edward Tilly
executiveIt's great to be here, Mike. Thank you.
Michael Carrier
analystThanks. [Operator Instructions]
Michael Carrier
analystSo maybe just to kick it off. If we take a look at the proprietary products and kind of step back, if I look at the past decade, Cboe has done a really good job. And if you look at the growth over time, it's been pretty consistent. You had years where it was extremely healthy. But obviously, more recently, it's been a little bit more muted and under pressure. I'm just curious, like, what do you think has changed, whether it's the user base? Or has it been mostly the environment, I mean, that has created kind of the current impact? And what could turn that around?
Edward Tilly
executiveI think you recognize, I think, the biggest change, the macro trading environment. If you look, historically unrecognizable. This is extremely prolonged uncertainty of the marketplace with 2 huge factors that really had no clarity as to when they were going to end. And we know what those are, the pandemic, and while there's really good signs that there's progress being made, there's still -- you can see, if you look at the VIX term structure, the longer-dated futures contracts still show that indifference surrounding the pandemic. And from the month, we saw greatly impacted with the election, not surprising that it happens in every cycle. But in this month, even more so. And we don't have total clarity there as far as what the market is telling us in the first couple of months. So that flat volatility surface is one of the greatest indifference from an institutional perspective. And we see that in the proprietary product, both the mix between SPX, VIX futures and options. And then just overall, engagement. Institutions have not participated, into a great extent, in this incredible move up in the market. Now that said, over the last couple of weeks, we've seen an engagement in VIX options and a reengagement in SPX options. So while the VIX futures still remain a bit -- trading the slowest or the least quick to return to trading, we've seen a lot of VIX options, a lot of SPX trade of late. So what we've told you all is playing out in the market, that institutions have been sidelined. We'll utility in the product set when they have in mind where the market will go over the next months, and then obviously, a longer cycle than that. So as I said, in the recent weeks, we've seen some return on the institutional trader.
Michael Carrier
analystAll Right. Good color. And then maybe just on that -- in terms of that backdrop, you guys have been more active on the strategic front. So when I look at the M&A activity, whether it was EuroCCP, BIDS, MATCHNow and others. So what's been driving kind of the pickup in M&A activity for Cboe?
Edward Tilly
executiveWell, let's look at the 2 categories. So -- and I think you've started to do that. If we look at what we've done in Information Solutions group, and that is the extension that you saw really mid-year with FT options Hanweck and Trade Alert. That is really rounding out that Information Solutions feud that was really started with LiveVol and then we added Silexx. And now really, for the more sophisticated trader offering pre-, at and post trade services, we don't let that integration play out, but we think we're in a really, really good spot offering a unique in combination or really picking along that those choice of offerings, all of our users can find much help in their pre-, post and at trade services by Information Solutions group. So really a good spot there. And if you look at M&A in the next category, that's either a global expansion or asset class expansion, that's where you'll see EuroCCP, BIDS and MATCHNow. And I don't think we're ever really going to be done looking at global expansion or asset class diversification. So a lot of the build in Europe, which was facilitated by buying EuroCCP, allows us to move into pan-European options using the technology on the base that we've built in Cboe's equity chain across Europe. And then in MATCHNow, part of our North American equities division, really our core business, very similar customer base and really comfortable with rules and regulations in Canada. And geography really, an easy move for us to operate out of North American equities. And then most recently, an announcement that we plan on closing our transaction with BIDS, a great partnership that we've enjoyed in large and scaled trading in Europe. And recognizing the great services that BIDS is offered in the U.S. that locked trading, not disintermediating by -- or the buy side and the sell side. We love the model and we think there's room for growth there. And immediately, what we called out that will continue to strengthen the U.S. -- bid presence in the U.S. and Europe with us already, and then we move into Canada. So everything really falling into place on M&A has been a very busy year, we recognize that. But in a pretty good spot right now.
Michael Carrier
analystOkay. Great. That's good color. And maybe just spending a little bit of time on EuroCCP and sort of 2 questions. First is, can you just provide some context on like what's missing in that market? I mean, like what's Cboe trying to provide? And how do you see that opportunity over time? And then separately, maybe for Brian, is just when you look at the revenue contribution in 3Q, it appeared to come in probably better than expectations. And so is that like a good run rate all else equal? Or was there anything unusual there?
Edward Tilly
executiveSo let me start, Brian, and then I think you can jump in. And we think that the European derivatives model has served benchmark European companies' final. This is not a share play for Cboe. So what we saw was an inefficiency and market model and an inefficiency in clearing. You need to clear pan-European risk in 3 different clearing houses today. We don't think that's optimal and EuroCCP will offer the same country-specific exposure and one clearing house, completely efficient, really easy to get to, easy access, we're about that. Market model. We think that the market has served the European investor, okay, but we know there's pent-up demand for continuous quoting in markets that are easily -- much more easily accessible, similar to the U.S. market model. So we're really just lifting up what we've learned in the U.S. and building out that capacity in -- more broadly across Europe so that the markets will represent and work very similar to a global user as what they're used to seeing in the U.S. market. It's that simple. It's a heavy lift, but the concept is pretty simple, and that's what we're on track to deliver mid-year next year. Brian, second part of the question?
Brian Schell
executiveYes. So I would say, Mike, good question. Thanks. That the -- it did come in a little stronger but I would say that the transaction volume through there was probably what we've seen historically. I think the one thing that was nuanced that we probably could have done -- provide a little bit more clarity to the investors and looking at those results is there was a little bit of a catch-up from something called our settlement efficiency fund that, once you put in a project or where you improve the settlement process, you recognize some -- maybe some pent-up revenues that you were accruing, for example. So when we made the acquisition and we put in place a line of credit to enhance their overall liquidity and settlement profile of EuroCCP, that released, I would say, a couple of million more revenues that was a little chunkier in the third quarter. So bottom line, if you look from a run rate perspective, it was probably a little bit more by a couple of million dollars in that quarter, which would normally be more spread out over the entire year. So if you're kind of looking to normalize that, that was probably the, I'll call it, a little bit more unique to the third quarter. But otherwise, much in line with what we expected from volume across the other revenue categories.
Michael Carrier
analystOkay. Great. Maybe just shifting over to U.S. equity. So that's an area where volumes have been very strong. You guys have multiple initiatives in place to kind of improve your positioning despite still fairly active like competition in that market. So how has the retail priority initiative work versus expectations, particularly just given the strength that we're seeing in the retail part of the market?
Edward Tilly
executiveWell, I think the retail party, in general, has been terrific. I mean, what Cboe is trying to do in U.S. equities is just not offer the same thing. And we're looking at what can we bring to the marketplace as this new, unique, while serving our customers a little differently or better. And customer priority is one of those things. We continue to grow customer -- priority continues to grow the share that we're trading on Ajax. There are now -- it's about 23-or-so percent of our average volume in Ajax. That's a big deal. So that means that there was demand, and the customers are finding utility in that priority. And we will continue to look for things that differentiate us from our competitors. And then I think more broadly, Brian, some comments on U.S. equity trading from you would be great.
Brian Schell
executiveYes. So I would say that what we've seen is, as you look at the entire perspective and where we've looked at it, it's not just been the retail prior to where we've done. This has been a -- as everybody knows, it's a highly competitive environment, a highly competitive market. So retail priority is one element as to what we're doing. We've continued to look at pricing, continued to balance that market share. We've implemented midpoint discretionary works. So there's a lot of things that we're doing to compete within the exchange environment of continuous trading. We're also then looking to how do we motivate flow that was going off exchange back into the exchange landscape. So you're seeing a very holistic approach and innovation that we're just going to continue to not rest on what's there, but continue to listen to the customers that are trading, how can we improve their experience and implement something that we think they'll find greater utilization in versus, hey, it's a commercial contract. I'm just going to try and get more revenue. So we think that's the best way to build kind of that long-term value for our shareholders by listening to customers and introducing vehicles that really enable them to have a better trading experience.
Michael Carrier
analystOkay, great. Brian, you mentioned just looking at like pricing and market share. And I think you guys have done a good job over time in balancing the 2 to make sure you're maximizing sort of the revenue opportunity. But given some of the competition, it mimics coming into the market. Pricing seems like it's moved the pie a little bit more than people have expected. But has anything shifted on how strategically you guys look at those 2 and how to try to maximize like the revenue opportunity in that market?
Brian Schell
executiveThat's a good follow up. Thank you. So we look at it. It's a long-term -- we look at it from a very long term, right? I mean the idea is we're charged with deliver long-term shareholder value. And one of those things that we think is important, part of that is the long-term value of what the North American Equities business is. And here, we're obviously just focusing on U.S. equities. And balancing that revenue growth and its total revenue growth over the long term, even if there might be a couple of, call it, shorter-term bumps. And as we continue to titrate the pricing to try and get that Goldilocks point of balancing, a really strong market share against an appropriate capture, to really how do we help make the net revenue growth over the long-term more effective because we want a very strong share to help continue to, obviously, generate the SIP revenues. It's important to continue to have a lot of value around our proprietary market data, continue to have a lot of value of people wanting access and capacity to our markets. So that movement is a little bit of art sometimes. We want to make sure when we put incentives in place it's -- it's incentive behavior that we want. And again, it's not just because you have new entrants coming into the market. We have new exchanges that came online. Like I said, I mentioned earlier, it is we want to attract from the existing exchanges, not just the new and competing against them. But it's also trying to, again, pull in some of that flow. It's like, how do we attract that flow that's going off-exchange on-exchange and make that attractive. So like I said, we're trying to provide a real holistic offering, continue to leverage our data analytics framework, providing customers with a sense of here's the value on trading with either this type of order or on this exchange and what they can expect from the TCA analysis and how their orders are really trading and their overall cost.
Michael Carrier
analystYes. It makes sense. And then maybe one more on the U.S. Equities business. You guys have had a partnership with bids. Now you're moving in with the acquisition. What do you see going on in that part of the market that makes you think that like having that within Cboe makes more sense kind of going forward?
Edward Tilly
executiveIt's not just in the U.S. market. So while bids began in the U.S. in very successful block trading platform, we like the model without disintermediating buy side and sell side, as I pointed out a bit earlier. But we had great success in Europe and our partnership with BIDS, like, in large and scale and bringing the block fitting mechanics to the European market for us. And then as I said, the opportunity to do so in Canada just continues to make sense. So BIDS in and of itself is an expandable platform. Block trading is a universal need, we think, from our customers who had exposure in different geographies. And we think there's an opportunity to expand. In the U.S. market, obviously, just off-exchange trading in general continues to grow. So our first foray into being able to compete off-exchange in this regard and block trading makes real sense for us, recognize the potential of BIDS outside of U.S. as well. So a perfect combination for us. The business that Tim Mahoney built with his team, we love it. We've gotten along incredibly well in Europe. The teams work closely together. We love the partnership and like the direction the teams move the company.
Michael Carrier
analystOkay. If we shift over to the options part of the business, like the multi-listed, that's also another area where volumes have been pretty active this year. There is a level of competition. But how are you guys continuing to try to differentiate in that space as there is still a pretty good level of competition, but you guys have kind of held your own?
Edward Tilly
executiveYes. It's not dissimilar to equities, super competitive. What can we bring to the market that either is being underserved by our customers or what can we do slightly differently and we continue to stay at the forefront of that. Many times, with Cboe, that's in contract construction and bringing new analysts in new exposures to the marketplace in different ways or more efficient ways. So we'll continue to press that. We've relaunched our XSP which is a mini version of the S&P 500 with a make-or-take pricing scheme just recently. So that is recognizing a need, we believe, that has not been filled for retail and exposure to the S&P 500 in a much more capital-efficient way than currently, spiders' offer. There are simple things that I think we need to continue to do. More broadly, the opportunity for retail is recognizing that the new retail investor has not been satisfied with either the products we offer or our competitors and/or the platform and the manner in which they're accessing our markets and we need to change. We need to catch up. So we see great opportunity to bring along, being in front of the move, a new retail into equity chain to teach derivatives and more complex strategies how to lower exposure, lower risk in a the portfolio while still being able to have either the same economic exposure, but in a much more efficient way. So incredible opportunity to offer education and new products to what we've seen is a very exciting engagement in new retail users.
Michael Carrier
analystOkay. And then just shifting over to the proprietary products. You guys have been active in launching additional index products over the past several quarters. Where are you seeing some of the more interesting demand when you have some of these product launches that you're kind of excited about?
Edward Tilly
executiveYes. I think it's important to note that as successful new products are years in the making. So if we look at iBoxx, completely new. A great uptick; month in, month out, we're seeing engagement and growth; normal rotation in the market, and we've seen a number of changes in investors' outlook just in this year and having a complete suite that gives you global U.S. dollar predominated exposure, having that complete set of products, very important for us and bringing our customers along. And that awareness and that education is very, very important. Of course, you referenced relaunches, I talked a little bit about XSP, great -- we see great potential there. But just mini contracted, mini exposure on the short-dated side. We know that's capturing the imagination of the new investor and actually, you'll see us focus, meaning this was a great launch. Over just the last couple of months, it's been just an incredible uptake in first, more sophisticated traders who are not trading the big VIX futures contract. And now a small and steady adoption of retail, who's finding the notional value of the new contract much more digestible and hitting a more traditional active retail account. So much work to do, but there'll be more on that front for sure.
Michael Carrier
analystGreat. Great. Great. And then just shifting to European equities. You mentioned, when we talked about BIDS, that there's some opportunity there. And in European equities, you guys have generally done well, even through Brexit. But just when you look at your market share today and you look at sort of the growth opportunity going forward, is there more from like a market share opportunity? Or is it more growing with the market, just given that you've been as successful as you have?
Edward Tilly
executiveI think there's both. There's always chance for us to grow and share. But I think right now, if we look across Europe, the opportunity is the entire region to grow, which is certainly around Brexit. It still is disruptive and lack of clarity, just like I observed in any market, it keeps some people sidelined until there is clarity. So I think we'll gain our pro rata share first as the market returns and traders return to their equity exposure. And then I think you'll see us pick up on share after that. It's difficult to get share attention when there's great uncertainty around the known event. And we find that not just in Europe, but more broadly as we look at markets across the globe. Brian, anything to add?
Brian Schell
executiveYes. I'm just going to really put a point on that last point, Ed, is, is that what we've seen historically is that we have competed very effectively even in this lower volume, lower volatility environment in the European trading environment. And that with incremental volume, I think you'll see a disproportionate -- what we've seen as a disproportionate, actually, amount of market share that we will gain as that continues to go up. Because I think you'll see more traditional trading patterns that Cboe's orders and its venue and everything that it provides, investors will be more attracted to than, say, in a lower-volume -- volatility, lower-volume environment.
Michael Carrier
analystOkay. Great. [Operator Instructions] I don't want to spend too much time on the FX margin because, on a relative basis, it's a little bit smaller. But when you think about some of the initiatives that you guys have worked on over time in that space, is there anything that can be on the horizon that could have kind of like jump-start or take you to sort of the next level in the foreign exchange market?
Edward Tilly
executiveLet me start more broadly. And then Brian, you can in with specifics. But gosh, just in the last week, it's not like what we've seen the return of the institutional investor in the U.S. market. The FX market has been incredibly exciting. So our volumes, like everyone's over the last weeks, have been great. So similar to your question on European equities, I think just the return in the interest in trading FX, as a point, when globally, that pops, we do quite well. And I'm really happy with our share in the growth and what the group has been bringing to the market. I think it continues to be unique. Our source liquidity in the manner which we do is unique, and that shows up in days like, as I say, over the last couple of weeks that we've seen just outstanding volumes. But Brian?
Brian Schell
executiveYes. And let me just -- to make a fine point on that is, is that as you've seen the overall volumes flattish, you've seen us continue to grow share. So Ed mentioned that uniqueness. It's that curated liquidity that in working with those participants that gives us an advantage. And again, you're hearing a continuous theme from us about listening to market participants and adjusting the model so that it's meeting their needs. And so this is perfectly done in the FX environment in which we operate of looking the different forms of providing a curated liquidity to everyone. I think you're seeing us offer a new order book that we've introduced that is brand unique, and that's adding -- getting a couple of yards on volume every day. And that's really starting to chunk up in market share. You see us starting to become more active in NDFs on and off set, and we've talked about those launches. Again, not material yet, but we see slow, steady progress. So it's -- again, it's just not resting. It's continuing to really listen and provide that curated liquidity and build the systems around it. So like I said, we're still very excited, very proud of that team and what they've been able to do in a very kind of, I'll call it, kind of a low overall volume environment.
Michael Carrier
analystAll right. Great. And then just shifting to market data or the non-transaction revenue part of the business. You guys have seen good growth most recently this third quarter, but even over the past year or so. I just wanted to get a little bit of context on what the team has been doing in terms of building that out. You've made some acquisitions to kind of round out the offering, but where is that business? Where are, like, the subscriptions? And what's that opportunity look like moving forward?
Brian Schell
executiveYes. So we continue to be very excited about this business. So there's a couple of points I'd like to touch on there to talk about kind of what's been driving it. I will -- we use this analogy, but there probably isn't a better one than -- although it's not as literal anymore. It's good old-fashioned shoe leather. It's wearing it out. It is what you -- you have your client representation out there. You are talking to people. And where we've seen a lot of growth is we continue to see our fair share of wins in the U.S.. We were looking for a -- equally as good, if not better, set of data but at a much lower cost. And in this environment where we're seeing fee compression that people can charge, having that cost savings, particularly on an enterprise level, is very, very compelling. But it's a long lead time. When you switch over what information's flowing into your systems, that's going to take some time. So this effort, you're seeing the fruits of this effort that started 2 years ago, if not longer. So it's good old fashioned wearing out the shoe leather, contacting the potential clients and providing a compelling offering. And it's very -- we are the, I'll call it, the price leader in this. I would say the second one is, as we continue to look at the broader environment of enhanced market data, particularly around the derivative space. That's a unique data offering that we have that no one else has. And we can continue to provide people with better information at pre-, post at trade, which we're seeing a lot come through the information services group that we kind of started the call talking about. We're seeing a really nice, I'll call it, revenue synergy within that's really starting to gain traction and providing people with what they want. And so that's been really nice growth as well. And I think -- and you look at the geography, we're seeing really strong demand in Asia and in Europe. And again, not just the U.S.. So you're having all of these compelling drivers that you're seeing show up in this low double-digit growth rate and year-over-year of what was already growing at a pretty nice clip. You're seeing demand on the access capacity fees. People, they're seeing more volumes, more volatility. And people are jumping in and saying, "I want more of that. I need more of that. This has been a good trading environment for us. We're going to go and get it." So we're seeing it on both fronts. And then finally, I will say, and just to emphasize the point that you made earlier about the growth. This is not coming at -- from citing changes. This is coming from unit growth and subscriber growth. So -- and we've been publishing over the last, call it, 24 months. When we look at the quarter over -- or the year-over-year growth from the prior quarter is that anywhere from, at a minimum, it's been at least 2/3. And some quarters, it's been 100% of the growth we're reporting has been unit or subscriber base, not pricing based. So I guess said, that's just basically the product has merit. People are coming forward to it. They want to use it. And we're just continuing to see the cumulative impact of a long lead time, and just basically, I'll call it, just working hard to make sure that people understand the product offering that we have.
Edward Tilly
executiveBrian, I think you have to move to [ SlingBurn ] from shoe leather, but I don't [ have anything to do with it. ]
Michael Carrier
analystOkay. With that, we'll transition to -- let's take one of the questions coming from the audience. It's on M&A. So the gist of it is as Cboe has been more active this year on doing some of the smaller, kind of bolt-on types of acquisitions and just in terms of the outlook, do you still see a lot of opportunity on that front? Or would you expect sort of the level that we've seen in the past to start to slow down. And from a capital standpoint, focus more on whether it's dividends, buybacks, more capital returns?
Edward Tilly
executiveYes, Brian will take the second half. But for the first half, it's really where I started describing what's been happening for us and the success we've had in closing these deals. I like where the Information Solutions group is right now. They're in a really heavy integration and really coming along exactly as we've been predicting and modeling in the offering in ISG. So that's the FT Hanweck for sure and Trade Alert, all in a pretty good spot. All times, as far as geography and asset class, we'll always be looking. But there's nothing urgent that we need to do, but we'll always keep our eye out for doing what we think we do really, really well and that is operating in exchange. And we think we have an advantage in technology that allows us to do so in the most competitive markets in a highly, highly efficient way. We understand the markets. We operate the markets really, really well, and we like that advantage and most of what we learn we can bring to other geographies and other asset classes. So pretty good spot now, but always, always looking. But Brian, I think more broadly there on capital, if not, on the M&A. What are our plans?
Brian Schell
executiveYes. If you think about the capital allocation, the good news is the -- for investors is that our approach has not changed. It is consistent. So -- and people want to rely on that. That's where we've been. I think it emanated from having -- or its foundation is having a healthy balance sheet to be able to continue to do what you've seen us done. It's a perfect example of our capital allocation approach, actually delivering exactly what we said we would do. And we said we're going to prioritize an annual dividend increase. We've done that. We've had double-digit in the mid-teens increases of our dividend in the last 3 years. We have bought back shares opportunistically, and you've seen that clearly in this year. But it also means that when some of the smaller M&A that you've seen us do, there's enough balance sheet capacity from free cash flow, a little bit of leverage that's enabled us to do that as well. So all of those factors, again, helping to drive that long-term value is very important to us. And I think we've just delivered exactly what we said we would do. So I said that, that's -- it hasn't changed. We'll continue to evaluate that on a go-forward basis, continue to evaluate the opportunities, as Ed said, continue to return cash to shareholders. Because at the end of the day, we don't want a lot of cash sitting on the balance sheet, not being deployed for the benefit of shareholders. And again, that's primarily through the annual dividend increases and then the share repurchases.
Michael Carrier
analystOkay. Great. And then maybe just moving over to expenses. You guys have managed cost well this year. And it -- a lot of stuff going on with some of the acquisitions, starting the year with robust volumes and then things started to trail off. But you guys have a pretty good handle on kind of balancing that. But just when you look at the outlook and you think about some of the investments that you're making, some of the acquisitions which are going to bring on cost on a full year basis. And then I guess on the other side, the areas that you're looking at, whether it's for efficiencies as everyone has been going through work-from-home, if that's opened up any opportunities. I just wanted to get a sense on how you're looking at in both -- like the growth areas, which are good for future kind of top line growth, but still trying to work on efficiencies and manage the shorter-term impact on, like, the volumes. So just an update there.
Brian Schell
executiveSure. So we're not quite ready to give 2021 guidance. And -- but I will kind of give you a little bit of a framework of how we're thinking about it because you brought up a lot of nice points that not just Cboe, but a lot of organizations are probably dealing with. First is, if you think about what's a good run rate as I continue to try and think about my preliminary models and how do I populate that and what does that look like? Is that -- the overall expense base that we've kind of talked about from the M&A, let's call it roughly $60 million that -- on an annual basis. And so if you're about halfway through, you know there's going to be incremental going into next year from what we had. So there's an incremental $60 million on top. Again, it's an annual basis, so call it roughly $30 million that we're going to have to just naturally just going to show up per se. We've talked about the derivatives build-out. And that's a business case where the expenses will come before the revenues. We talked about them when we made the acquisition of EuroCCP that, hey, that while the acquisition itself was slightly accretive to neutral, the investment spend and the derivatives build-out, both at the exchange level as well as at the clearing level, that's another $15 million of expenses that's going to translate into -- that's going to come before the revenues come. And we've kind of -- and we shared that, obviously, when we made the acquisition. And then obviously, then we're going to continue to look for those efficiencies along the way as well as balancing the core growth initiatives. How do we continue to drive revenue growth in each of our products, particularly the proprietary, and those underlying efforts. So that's the general framework, I think, that is a way to think about kind of that expense base. And again, we'll continue to try and -- we'll continue to have built in is that natural incentive compensation that is self-correcting. Should our revenue not hit where we want it to be or where we've targeted and where we're incented to do, there's going to be a natural attention to that as well if we get -- it we're not growing the way we want.
Michael Carrier
analystAll right. That's good color. And Brian, just one other question is on expenses. When you think about like the variable, say, portion of the expense base, like exchanges just generally, our view is having like a ton of variables just because there's a lot of fixed costs, but you also have attractive margins. But it does seem like comp is one of those, like the incentive comp, that tends to fluctuate depending on how the euro pans out. What else, to you, does tend to be a variable? And how significant is that incentive comp variable?
Brian Schell
executiveYes. I would say that we are no different. When we -- when revenue grows, you can get such a high contribution of that revenue dollar to the bottom line. I guess the compensation is roughly half of our adjusted operating expenses we've guided to, roughly that $415 million to $420 million for '20; and comps, roughly half of that number. And I would call the incentive part of that, that's variable kind of a year-over-year. That's a 15% to 20% of that number. So it can be sizable depending on that. The thing that also is, as we look at the, call it, the COVID-related or the pandemic-related expenses that were essentially not incurred this year, should we return to a more traditional work in the office environment and you'll see a pickup in travel. Our structural costs really didn't change that much because it's been really more around some of those travel, some of the things we provide for associates that are more office-based, that's probably a $5 million to $7 million number that's just not that big that doesn't materially change our cost base. It's nice to get when it happens and we're going to make sure we deliver to the bottom line. But then we're going to reinvest it when we kind of think that the environment has renewal, but be very rational. Do we still need to make that extra trip? Or, hey, I think these video things are working really well, but I do think there's going to be a blend kind of going forward. And where that balance is, we'll see. Because we also have to have the clients saying, yes, we're ready to take your visits as well. So it'll take a while to restore it to natural levels.
Michael Carrier
analystOkay. That makes sense. And then we just take one more from the audience, a few minutes left. But -- and this is more on the regulatory side. So just with the election and kind of post election, some of the items have taken a little bit of a backseat just in the more near term. But do you see anything changing on the regulatory landscape, whether it's new areas in the business? Or things that -- whether it's the SEC that has been focused on that could either shift going forward?
Edward Tilly
executiveYes. I hope -- I'm encouraged, first, by what we learned early days in the pandemic when we had closed the trading floor. The cooperation with the SEC reminded me of a more normal relationship with China Exchanges in the SEC. That means a very healthy tension but always a shared vision of what's pass for the investing public. And we worked well together with the SEC and I think that serves as an ideal model going forward. I'm hopeful with the change in administration that we can get back to that relationship with the SEC. We are all in this, in the lit markets, those of us that open the exchanges each and every day to serve investors. And the SEC, that is their calling, and we need to be aligned with that. I think the SEC has got a little off track and a little ambitious in trying to attack a lot of the market that just doesn't need to be attacked or under the screening that has been over the past few years. But with any administration, there's a recalibration. I'm very optimistic, as I say, that the template that we use through this crisis is a great one, and it's very, very promising for the future.
Michael Carrier
analystGreat. With that, we're out of time, but we'll wrap it up there. But Ed and Brian, I want to thank you for participating today. I really appreciate it. And hopefully, next year, we'll be back in person.
Edward Tilly
executiveHopefully. Great to see you, Mike. Thank you.
Brian Schell
executiveThanks, Mike. Bye.
Michael Carrier
analystBye.
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