MARKET REGULATION ADVISORY NOTICE______________________________________________________________________
Exchange

CME, CBOT, NYMEX & COMEX

SubjectDaily Submission of Large Trader, Ownership/Control Reports,
and Open Interest Data

Rule References

Rule 561

Advisory Date

September 28, 2020

Advisory Number

CME Group RA2014-5

This Advisory Notice supersedes Market Regulation Advisory Notice RA1713-5 from September 26,
2017, and is being issued as a result of the extension of the CFTC’s Division of Market Oversight’s NoAction relief set forth in CFTC Letter 20-30 issued on September 25, 2020.
Under the extension, the volume threshold for reporting volume threshold accounts on CFTC Form 102B
will remain at 250 contracts until the earlier of: (a) the applicable effective date or compliance date of a
CFTC action addressing the reporting volume threshold or (b) September 29, 2023.
This Advisory Notice continues to reflect changes to Rule 561 in connection with the CFTC Ownershipand Control Reports (“OCR”) rule. As noted in Market Surveillance Notice # MSN11-04-14 (“MSN11-0414”) from November 4, 2014, CME, CBOT, NYMEX and COMEX (“the Exchanges”) require submission ofnew CFTC Forms 102A and 102B in line with the CFTC OCR rule and require that the new forms besubmitted to the Exchanges in the same form and manner as required by the CFTC’s OCR rule. The
Exchanges accept submissions of new CFTC Forms 102A and 102B in XML formatted files (as specifiedin the CFTC OCR rule), or manual submissions of the new CFTC Forms 102A and 102B through theenhanced Firm Regulatory Portal (“FRP”). The XML formatted files can be submitted with the following
filename:
PFTP_OCR_XCME_[FIRMID]_[YYMMDD]_[HHMMSS].xml or
PFTP_OCR_XCME_[FIRMID]_[YYMMDD]_[HHMMSS]_[UNIQUIFIER].xml
The text of CME/CBOT/NYMEX/COMEX Rule 561 appears at the end of this Advisory Notice.
CFTC Form 102A Submission
Reporting parties are required to provide the Market Regulation Department (“Market Regulation”) with anelectronic submission of CFTC Form 102A (“Identification of Special Accounts”) which accurately
identifies the owners, controllers, controlled accounts and any additional information required on the formfor each account that becomes reportable for the first time.
Complete CFTC Form 102A information must be provided within three (3) business days of the first date
the account becomes reportable. However, Market Regulation requires preliminary account information
including Special Account Origination, Reporting Number and Name and House or Customer Indicatorwithin one (1) business day of the first date the account becomes reportable.
Market Regulation requires an updated report for accounts with material changes that cause theinformation previously submitted to be inaccurate. The updated reports are required to be submitted
within three (3) business days of such changes becoming effective. A material change includes changeof account name, address, owners, controllers, or controlled accounts. Notwithstanding the above,
Market Regulation may also request an update on an as-needed basis for any account as it deems
necessary.

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September 28, 2020
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Where notification has been provided to the CFTC that an account has been deemed expired/closed,
Market Regulation must be provided a similar notification.
CFTC Form 102B Submission
Clearing members are required to provide a new CFTC Form 102B for any trade account that meets thevolume threshold of 250 contracts or more in a single trading day.
Complete CFTC Form 102B information must be provided within three (3) business days of the first date
the account becomes reportable under the revised rule. However, Market Regulation requires preliminaryaccount information such as, Trading Account Data for the Volume Threshold Account, AssociatedSpecial Account Number and Volume Threshold Account Owner(s) within one (1) business day of the firstdate the account becomes reportable.
Market Regulation requires an updated report for accounts with material change that causes theinformation previously submitted to be inaccurate. The updated reports are required to be submitted
within three business days of such changes becoming effective. A material change includes change ofaccount name, address, owners, controllers, or controlled accounts. Notwithstanding the above, MarketRegulation may also request an update on an as-needed basis for any account as it deems necessary.
Where notification has been provided to the CFTC that an account has been deemed expired/closed,
Market Regulation must be provided similar notification.
CME Group Firm Regulatory Portal
The CME Group Firm Regulatory Portal (“FRP”) provides various reports and screens to assist inaccurate and timely account and position reporting.
The FRP has been enhanced to allow reporting clearing firms the capability to generate a large trader
and open interest comparison report (“Misreporting Report“) by product, contract month and, for options,by strike price. The Misreporting Report also allows clearing member firms to query reported positions
and to utilize static queries to assist in identifying additional potential reporting discrepancies such as
potential offsets and over- or under-reporting of positions. Market Regulation strongly encourages firms
to utilize this functionality to assist in the identification of potential reporting discrepancies in order toensure that any necessary adjustments are submitted by the established adjustment deadlines.
The FRP has been recently enhanced to assist clearing firms and omnibus accounts in OCR reporting.
An Unidentified Special Accounts Reports allows reporting firms to identify CFTC Forms 102A and 102B
accounts for which Market Regulation does not have any account information. The FRP portal also
contains screens that will allow reporting firms to manually enter account information for CFTC Forms
102A and 102B accounts.
The FRP can be accessed at https://fltr.cmegroup.com/firmregulatoryportal/logon.jsp using a registered
CME Group Login and requesting access to MarketRegLTRAlerts@cmegroup.com. Registration
instructions for obtaining a CME Group Login may be found at FRP homepage. For technical issues
please email MarketRegLTRAlerts@cmegroup.com.
A manual is available on the FRP.
Omnibus Account Reporting
Omnibus accounts that carry reportable positions pursuant to Rule 561 must submit reportable largetrader positions directly to the Market Regulation Department via Secure FTP (“SFTP”) to the CME Group
File Server. Omnibus reporting entities may submit large trader positions using the CFTC-assigned alphafirm ID. If an omnibus entity does not currently submit large trader positions and is not set up to submit
via SFTP, the entity should contact the Market Regulation Department Large Trader Group to obtain

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September 28, 2020
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further reporting instructions. The omnibus entity may use the following large trader file layout:
http://www.cftc.gov/IndustryOversight/MarketSurveillance/LargeTraderReportingProgram/ltrformat.html
In order to ensure accurate open interest and large trader positions, clearing members are required toobtain timely offset instructions for all accounts they carry, including omnibus accounts. Clearing
members are responsible for the accurate position reporting of accounts carried on their books on anomnibus basis. Accordingly, clearing members must have appropriate procedures in place to ensure thethat any position offsets for omnibus accounts are reported in a timely manner, no later than theestablished adjustment deadlines set forth below.
CFTC Form 40 Submission
Market Regulation may require submission of CFTC Form 40 in any instances it deems necessary.
Accurate and Timely Reporting Requirements
All clearing firms and omnibus accounts are reminded that it is their responsibility to accurately report
open interest, large trader positions and, where applicable, long positions eligible for delivery consistent
with required submission deadlines. This requirement includes ensuring that open interest and large
trader positions resulting from option assignments are accurate.
Open Interest (PCS) Submission:

6:00 p.m. CT / 7:00 p.m. ET for NYMEX and COMEX products
7:30 p.m. CT / 8:30 p.m. ET for CME and CBOT products

Open Interest (PCS) Adjustments:

The deadline for PCS adjustments for all CME Group Exchanges
is 8:15 a.m. CT / 9:15 a.m. ET

Large Trader Submission:

7:00 a.m. CT / 8:00 a.m. ET for all CME Group products

Large Trader Adjustments:

9:00 a.m. CT/10:00 a.m. ET for all CME Group products.
Error corrections or any other adjustments to the large trader
position file may be completed using the web-based Firm
Regulatory Portal (“FRP”) portal application.

Positions at or above the reportable level in a particular expiration month of a futures contract, or in all
puts or in all calls of a particular option contract expiration month, are required to be reported. For anaccount with reportable positions in a particular contract, all positions, regardless of size, in any contract
month and in any contract that aggregates with that contract must be reported. The Position Limit,
Position Accountability and Reportable Level Table at the end of Chapter 5 of each Exchange’s Rulebookestablishes the aggregation relationship. If an account is reportable in any contract, all “Aggregate Into”
contracts noted in the spot-month, single month and all month aggregate into futures equivalent leg (1)and leg (2) columns of the Position Limit, Position Accountability and Reportable Level Table at the end ofChapter 5 of each Exchange’s Rulebook should be reported.
Failure to comply with any of the above reporting requirements may result in sanctions pursuant to CME,CBOT, NYMEX and COMEX Rule 512.
Questions regarding this Advisory should be directed to the following Market Surveillance Staff:
Sandra Valtierra, Manager, 312.347.4137, or Sandra.Valtierra@cmegroup.com
Danyelle Franks, Sr. Database Integrity Admin., 312.341.7646, or Danyelle.Franks@cmegroup.com
Erin Middleton, Director, Rules and Regulatory Outreach, 312.341.3286 orErin.Middleton@cmegroup.com

CME Group RA2014-5
September 28, 2020
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Paige Gawrys, Senior Specialist, Rules & Regulatory Outreach, 312.872.5078 orPaige.Gawrys@cmegroup.com
For media inquiries concerning this Advisory Notice, please contact CME Group Corporate Communications at312.930.3434 or news@cmegroup.com.

CME/CBOT/NYMEX/COMEX
Rule 561. SUBMISSION OF LARGE TRADER POSITIONS AND VOLUME THRESHOLD ACCOUNTS
561.A. Large Trader Reporting
Clearing members, omnibus accounts and foreign brokers shall electronically submit to the Exchange a daily large
trader position report of all positions required to be reported as set forth in the Position Limit, Position Accountability
and Reportable Level Table, in the Interpretations Section at the end of Chapter 5.
Positions at or above the reportable level in a particular expiration month of a futures contract, or in all puts or in allcalls of a particular option contract expiration month, are required to be reported. For an account with reportable
positions in a particular contract, all positions, regardless of size, in any contract month and in any contract that
aggregates with that contract must be reported.
The daily large trader position report submitted to the Exchange must also include, for each reportable account, 1) theEFRP volume bought and sold in the reportable instrument, by contract month, and for EOOs by put and call strike and2) the number of delivery notices issued and the number of deliveries stopped in the reportable instrument.
In addition to the large trader position report, clearing members, omnibus accounts and foreign brokers must
electronically provide the Exchange with the required CFTC Form 102A (“Identification of Special Accounts”) accurately
identifying the owners, controllers, controlled accounts and any additional information required for each reportableaccount within three business days of the first day that the account in question becomes a reportable account.
Notwithstanding the three business day submission requirement, on the first day that an account becomes reportable,clearing members, omnibus accounts and foreign brokers must, at the direction of the Exchange, provide the following
information: account type, reportable account number and names and addresses of the owners and controllers of theaccount.
The Exchange may require that more than one large trader position report be electronically submitted daily. The
Business Conduct Committee or the Market Regulation Department may require reports or additional accountidentification from any clearing member, omnibus account or foreign broker on a lesser number of positions thanreflected in the Position Limit, Position Accountability and Reportable Level Table.
If any material change causes the information previously submitted to the Exchange to become inaccurate, then suchclearing member, omnibus account or foreign broker must electronically submit to the Exchange an updated form
reflecting the accurate information within three business days of such changes becoming effective. Additionally, in theabsence of any material changes, the Exchange may require the electronic submission of a new form on an annual
basis for the maintenance of accurate records. A material change includes, but is not limited to, change of accountname, address, controllers or controlled accounts.
561.B.
Volume Threshold Reporting
A volume threshold account is any account that meets the volume threshold of contracts traded in a single trading day
as defined in CFTC Regulation 15.04. Clearing members, shall electronically submit to the Exchange the required
CFTC Form 102B (“Identification of Volume Threshold Accounts”) accurately identifying account information for volumethreshold accounts, including the owners, controllers, controlled accounts and any additional information required by
the report within three business days of the first day that the account in question becomes a volume threshold account.
Notwithstanding the three business day submission requirement, on the first day that an account becomes reportable,clearing members, omnibus accounts and foreign brokers must, at the direction of the Exchange, provide the following
information: account type, reportable account number and names and addresses of the owners and controllers of theaccount.
If any material change causes the information previously submitted to the Exchange to be inaccurate, then such clearing
member, omnibus account or foreign broker must electronically submit to the Exchange an updated form reflecting theaccurate information within three business days of such changes becoming effective. Additionally, in the absence ofany material changes, the Exchange may require the submission of a new form on an annual basis for the maintenanceof accurate records. A material change includes, but is not limited to, change of account name, address, controllers orcontrolled accounts.
561.C.
Obligations of Omnibus Accounts and Foreign Brokers
Failure by an omnibus account or foreign broker to submit required information may result in a hearing by the BusinessConduct Committee and result in limitations, conditions or denial of access of such omnibus account or foreign broker
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September 28, 2020
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to any Exchange market. Notwithstanding the above, clearing members carrying such accounts remain responsible
for obtaining and providing to the Exchange information regarding the ownership and control of positions incircumstances where an omnibus account or foreign broker has failed to provide the information to the Exchange.
Clearing firms must require their clients to provide accurate and timely owner and control information, including anymaterial changes.
Upon request from the Exchange, clearing members, omnibus accounts and foreign brokers must provide CFTC Form
40.
561.D. Reportable Levels
The large trader reportable levels for all contracts are set forth in the Position Limit, Position Accountability
Reportable Level Table in the Interpretations Section at the end of Chapter 5.

and

Any trading account with a trading volume of 50 or more contracts during a single trading day, in a particular expiration
month of a futures contract or in all puts or in all calls of a particular options contract expiration month is a reportable
volume threshold account. [Pursuant to current CFTC No-Action relief, the current threshold is 250 or more contracts
for purposes of being deemed a reportable volume threshold account.]