MARKET REGULATION ADVISORY NOTICE
Exchanges

CME, CBOT, NYMEX & COMEX

Subject

CME Globex Operator ID Requirements

Rule References

Rule 576

Advisory Date

September 2, 2020

Advisory Number

CME Group RA2012-5

Effective Date

September 17, 2020

Effective on trade date September 17, 2020, and pending all relevant CFTC regulatory review periods,
this Advisory Notice will supersede CME Group Market Regulation Advisory Notice RA1902-5 from March7, 2019. It is being issued to harmonize references to Globex Terminal Operators and the way that suchparties are to be identified to the Exchange by replacing references to Tag 50 IDs with “operator ID.”No other material changes have been made to the Advisory Notice.
Rule 576 (“Identification of Globex Terminal Operators”) requires that each Globex Terminal Operator be
identified to the Exchanges by the submission of a unique operator ID. For CME iLink, operator IDs areissued by an Exchange Clearing Member firm (“Clearing Member”) or their contracted vendors orassignees, or in some circumstances, by the CME Group Global Command Center (“GCC”).
Clearing Members are responsible for ensuring that all operator IDs are unique at the Clearing Member
level and that all non-administrative messages (“messages”), inclusive of orders, sent to Globex areproperly submitted with the correct operator ID. Operator IDs are not case sensitive and Clearing
Members must ensure that uniqueness is achieved by means other than solely modifying the letter casebetween different operator IDs (For example, “ABC” and “abc” would be viewed as the same operator ID).
Further, all operator IDs must be between 2 and 18 bytes (characters) in length, and the Market Regulation
Department (“Market Regulation”) strongly encourages the use of alphanumeric characters only. If theoperator ID contains non-alphanumeric characters, the only characters permitted are as follows:_:@.

underscore
dashcolon(commercial) at
periodWith respect to accounts that are carried by Clearing Members on a disclosed basis, Clearing Members
must provide the identity of the “Individual” or “Team” assigned to each operator ID associated with theClearing Member immediately upon request by Market Regulation. Clearing Members must maintain orcause to be maintained historical records related to the identity of the “Individual” or “Team” assigned toeach operator ID for a minimum of five years.
With respect to omnibus accounts that are carried by a Clearing Member on an undisclosed basis,
Clearing Members must be able to either obtain and provide the identity or require the omnibus account toobtain and provide the identity of the “Individual” or “Team” assigned to each operator ID within theundisclosed omnibus account immediately upon request by Market Regulation. Clearing Members must
maintain or cause to be maintained historical records related to the “Individual” or “Team” assigned to eachoperator ID for a minimum of five years. Such historical records need not include the identity of the“Individual” or “Team.”
For operator IDs which require registration, it is the responsibility of the Clearing Member to ensure that

CME Group RA2012-5
September 2, 2020
Page 2 of 6each operator ID is properly registered in the Exchange Fee System (“EFS”). Registered operator
IDs must be identified as either “Individual” or “Team” in EFS, and all registrations must be current
and accurate at all times.
The text of Rule 576 is set forth below and is followed by a Frequently Asked Questions (“FAQ”)
section which begins on page 4.
576.

IDENTIFICATION OF GLOBEX TERMINAL OPERATORS
Each Globex Terminal Operator shall be identified to the Exchange, in the manner prescribed by theExchange, and shall be subject to Exchange rules. If operator IDs are required to be registered with theExchange, it is the duty of the clearing member to ensure that registration is current and accurate
at all times. Each individual must use a unique operator ID to access Globex. In no event may a person
enter an order or permit the entry of an order by an individual using an operator ID other than theindividual’s own unique operator ID.

Required Registration of operator IDs
Registration of operator IDs is required for individual members, employees of individual members,
employees or contractors of a Clearing Member, CME and CBOT Rule 106.J. (“Equity Member Firm”)
and NYMEX and COMEX Rule 106.J. (“Member Firm”) firms. Additionally, operator ID registration isrequired for any other party receiving preferential fees in accordance with other programs offered byany of the Exchanges, unless the terms of a specific program specifically exempt such registration.
Additionally, irrespective of whether a party is eligible for preferential fees, Market Regulation or theGCC reserve the right to require the registration of the operator ID of any market participant.
EFS supports the registration of operator IDs that are not otherwise required to be registered if theClearing Member elects to register the “Individual” or “Team” operator IDs. Trading entities must
provide accurate and up-to-date registration information about their “Individual” and “Team” operatorIDs to their respective Clearing Members. The operator ID that is registered in EFS must exactly matchthe operator ID that is submitted on all messages sent to Globex.
For “Team” registrations, EFS allows for the input of the relevant individual registration information foreach person on the team, and also requires the designation of each team member’s role. Available
roles include: Head Trader, Risk Monitor, Technical/Program Manager, Trader and Trading Monitor.
Each “Team” must have a Head Trader, typically the most senior person or the person primarily
responsible for the “Team’s” activities. If there are changes to the composition of the group of persons
represented by the “Team” operator ID, it is the responsibility of the trading entity and the Clearing
Member to ensure that those changes are promptly and accurately reflected in EFS.
Identification of operator IDs for “Individual”
An operator ID should be identified as an “Individual” if the operator ID meets one of the descriptions
below:••A single person who is a manual trader, which refers to a person who physically submits
messages directly into Globex using a front-end system, typically via keyboard, mouse, or
touchscreen, and the messages are then routed in their entirety to the match engine at the time ofsubmission.
A single person who is solely responsible for, and actively monitors at all times, the administrationand operation of an Automated Trading System (“ATS”). An ATS refers to a computer system
which generates and/or routes messages without human intervention. This includes anymessages generated by a computer system or routed using functionality that manages thesubmission of an order through automated means (i.e. execution algorithm). The person in thisrole typically initiates or disables particular algorithms or strategies, adjusts the parameters of any

CME Group RA2012-5
September 2, 2020
Page 3 of 6•

automated program(s), and monitors the live trading of the ATS. All messages must be submittedwith the “Individual” operator ID assigned to the person present at the time of operation.
A single person who engages in a combination of the trading methods described above. The
person must ensure that all messages are submitted with the correct manual order indicator todifferentiate between manual and automated activities.

Each “Individual” operator ID must represent a single person. Each person is required to submit
messages using their own operator ID and may not, under any circumstances, permit another person
to enter messages using their operator ID.
Identification of operator IDs for “Team”
An operator ID should be identified as a “Team” if the operator ID represents a group of persons whoare simultaneously administering, operating, and monitoring an ATS while it is operational.
Many ATSs are administered, operated, and monitored over the course of multiple shifts throughout atrading cycle. If the makeup of the group of persons is altered at the shift change time, or if a new groupof persons takes over the duties of the prior group at the shift change time, a separate unique “Team”operator ID is required for messages submitted to Globex during the new shift. Where registration isrequired, the group of persons on the new shift must be registered with a unique “Team” operator ID inEFS so that, at any given time, the operator registration accurately identifies the Team actively monitoring
the operation of the ATS.
A single operator ID may be used to represent multiple operators only in true ATS Team situations.
Entities may not bundle all their ATS operators under one operator ID if certain operators are primarily
responsible for different ATSs or for the same ATS on different shifts.
“Team” operator IDs may submit only automated messages to Globex. Should a situation occur where a“Team” needs to submit a manual message (i.e. during maintenance downtime, system malfunction, etc.),
the message must be submitted with an “Individual” operator ID assigned to the specific single person
submitting the message, rather than the “Team” operator ID associated with the group. In this scenario, aperson would be acting in the capacity of an “Individual” manual trader as described above.
Clearing Members must ensure that all operator IDs which require registration are currently andaccurately registered in EFS and must make any necessary updates to operator ID registrations
promptly. Failure to transmit operator IDs to Globex in accordance with this Advisory Notice may
result in disciplinary action and may also result in a reassessment of fees.

Frequently Asked Questions (FAQ)
Identification and Registration of Globex Operator IDs (operator IDs)
1. What is an administrative message?
Administrative messages, which are not subject to the requirements set forth in this Advisory Notice,include the following: Logon, Heartbeat, Test Request, Resend Request, Session Level Reject,
Business Level Reject, Sequence Reset, and Logout.
2. Do messages submitted to Globex require the submission of an accurate operator ID?
Yes. All messages other than administrative messages referenced in the answer to Question 1 above
must include the unique operator ID of the “Individual” or “Team” submitting such messages toGlobex.

CME Group RA2012-5
September 2, 2020
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3. What is an operator ID?
An operator or Operator ID is a user ID that uniquely identifies a party that accesses and/or submits
messages to Globex. operator IDs are issued by exchange Clearing Members, or their contracted
vendors or assignees, or in some circumstances, by the GCC.
4. Is the operator ID submitted on a message visible to other market participants?
No. Trading on Globex is anonymous.
5. Rule 576 states that each individual must use a unique user ID to access Globex. Is it
permissible for an individual to have multiple operator IDs?
Yes, an individual may have multiple operator IDs. However, each Clearing Member must be able touniquely identify the individual assigned to a particular operator ID or identify the individuals assignedin the case of a Team operator ID. To the extent an operator ID is issued to a participant trading
through an undisclosed omnibus account, the Clearing Member must be able to either obtain andprovide the identity or require the omnibus account to obtain and provide the identity of the“Individual” or “Team” assigned to each operator ID within the undisclosed omnibus account uponrequest by Market Regulation.
6. Are Clearing Members responsible for ensuring that operator IDs are unique at the Clearing
Member level?
Yes, all operator IDs must be unique at the Clearing Member level, irrespective of whether theaccount is carried by the Clearing Member on a disclosed or undisclosed basis.
7. Is there any circumstance in which a person may use the operator ID of another person?
No. Each message submitted to Globex must reflect the operator ID of the person or team ofpersons who submitted the message or caused the message to be submitted.
8. If a person deploys an ATS and someone else monitors the operation of the ATS duringcertain hours, does the operator ID of the person monitoring the ATS have to be entered on
new messages?
Yes. The operator ID on all messages must be the operator ID of the person responsible formonitoring the operation of the ATS at that time.
9. If a person deploys an ATS that operates for extended time periods, for example during
Regular Trading Hours in addition to European and/or Asian trading hours, may that person’soperator ID be sent on all messages?
The operator ID on the messages must reflect the person responsible for operating and monitoring
the ATS at the time the messages are sent to Globex. To the extent a single individual is responsible
for operating and monitoring the ATS over any given timeframe (e.g. more than one trading session
or more than a typical work shift), the individual’s operator ID is required to be submitted on all
messages. However, upon request, the individual must be able to demonstrate an effective means tomonitor the ATS during all times it is operating. During the times that a person is not actively either
operating or monitoring the trading operation of the ATS, their name should not be reflected on theactive operator.

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10. If a trader enters manual messages but also uses automated spreading functionality, may allof those messages be submitted under a single operator ID?
Yes, in this situation, a single operator ID may be used for both manual and automated messages.
The manual order indicator value submitted with each message must appropriately identify whether
the message was submitted via automated or manual means.
11. What is a “Team operator ID”?
If multiple individuals simultaneously work together to operate or monitor the operation of an ATS,
they may be assigned a single operator ID, called a Team operator ID, which represents all of theindividuals on the team. The registration process in EFS for a Team operator ID allows a firm toidentify the role of each particular individual on the team, for example, Head Trader, Trader, RiskMonitor, Trading Monitor, Technical/Programmer, or Other. Each Team operator must have a HeadTrader.
12. May a single Team operator be used for an ATS that operates for extended time periods, forexample during Regular Trading Hours as well as European and Asian trading hours?
No, because individuals on a Team operator must be simultaneously working together, and it isexpected that the Team operator ID submitted on messages will change as team members' shifts
change. For example, if a new team or a team with a different composition takes over the operationof an ATS during European or Asian trading hours, or any other time period or shift, then that newteam's Team operator ID must be used for all messages submitted during that period.
13. If a person is financially responsible for, and makes or oversees decisions related to an ATS,may that person be listed as the Head Trader on the Team operator ID for every shift during
which the ATS operates?
No. The Team operator ID must represent the team simultaneously working together to operate
or monitor the operation of an ATS at any given point in time.
14. If a person is working in a risk management function for a trading entity and as part of the riskfunction reviews and monitors the multiple ATSs that the entity is operating, does that risk
person need to be identified via a Team operator ID?
No, risk managers that are reviewing overall firm exposures and that are separate from the trading
function are not required to be identified on a Team operator ID. However, if the risk manager were to
manually intervene with the ATS they would need to do so using their own unique operator ID.
15. If a member of a Team that monitors the operation of an ATS needs to submit manual
messages, should the Team operator ID be submitted on those messages?
No. The Team operator ID may be used only for messages that are generated from the ATS. To theextent the team needs to submit manual messages, the individual operator ID of the person who
manually submits the message must be used.
16. Is there a limit on the number of ATSs an entity or individual may operate?
There is no limit to the number of ATSs an entity or individual can operate, subject to their ability toeffectively monitor the operation of the ATSs.
If you have questions on the Exchange fees applicable to an ATS operator, please contact the Fee
System Hotline at 312.648.5470 or via email at efsadmin@cmegroup.com.

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17. What information is required when registering an operator ID?
Information related to operator ID registration is available in the Exchange Fee System (EFS) User
Manual available at www.cmegroup.com.
18. What types of violations related to operator IDs will Market Regulation seek to identify?
Market Regulation’s review of operator IDs will be focused on, but not be limited, identifying thefollowing types of violations:•••••

Missing or Inaccurate Registration
Non-Identifiable Operators
Invalid Use of Operator ID
Invalid Operator ID Format
Inaccurate Manual Order Indicator Submission

Questions regarding this Advisory Notice may be directed to the following individuals in MarketRegulation:
Betsy Schneider, Manager, Data Investigations, 312.341.3343
Laetizia Moreau, Senior Director, Data Investigations, 312.435.3619
Andrew Carr, Investigations Specialist, Data Investigations, 312.435.3610
Lou Abarcar, Data Investigations Architect, Data Investigations, 312.341.3236
For fee-related questions or for general assistance with the fee system, please contact the Fee
System Hotline at 312.648.5470 or send an email to efsadmin@cmegroup.com.
For media inquiries concerning this Advisory Notice, please contact CME Group Corporate Communications at 312.930.3434 ornews@cmegroup.com.