SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 22-146 (4 of 4) 

Organization: Commodity Exchange, Inc. ("COMEX")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 04/12/22 Filing Description: Amendments to the CME, CBOT, 

NYMEX, and COMEX Hedge Exemption Form

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: See filing.

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Official Product Name: 

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

 Official Name(s) of Product(s) Affected: Rule Numbers: 
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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Christopher Bowen

Managing Director and Chief Regulatory Counsel

Legal Department

April 12, 2022

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: CFTC Regulation 40.6(a) Certification. Amendments to the CME, CBOT, NYMEX, and 

COMEX Hedge Exemption Form.

COMEX Submission No. 22-146 (4 of 4)

Dear Mr. Kirkpatrick:

Pursuant to Commodity Futures Trading Commission (“CFTC” or “Commission”) Regulation 40.6(a), 

Chicago Mercantile Exchange Inc. (“CME”), The Board of Trade of the City of Chicago, Inc. (“CBOT”), New 

York Mercantile Exchange, Inc. (“NYMEX”), and Commodity Exchange Inc. (“COMEX”) (collectively, the 

“Exchanges”) hereby certify to the Commission amendments to CME, CBOT, NYMEX and COMEX Hedge

Exemption Form (the ”Form”) (collectively, the “Rule Amendments”) effective on April 27, 2022.

Specifically, the Rule Amendments will amend the following three (3) sections of the Form as follows: (i) 

“Pass-Through OTC Swaps” - the pass-through swap certification will be a stand-alone question; ii) 

“Commodity Index Exposure” - allow participants to respond by applying historical commitments; and iii) 

“Spread Transactions” - separate spot month exposures from single and all-month exposures. The Rule 

Amendments are not substantive in nature and are intended to provide enhanced convenience for market 

participants and greater clarity.

The Exchanges reviewed the designated contract market core principles (“DCM Core Principles”) as set forth 

in the Commodity Exchange Act (“CEA” or “Act”) and identified that the Rule Amendments may have some 

bearing on the following Core Principles:

Compliance with Rules: As required under this Core Principle, compliance with Rule 559. will be 

enforced by the Market Surveillance team within the Market Regulation Department.

Position Limitations or Accountability: The Rule Amendments are expressly intended to comply 

with the requirements of this Core Principle.

Availability of General Information: The Rule Amendments will be posted publicly on the CME 

Group website in satisfaction of this core principle.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.6(a), the Exchanges certify that the Rule 

Amendments comply with the Act and regulations thereunder. There were no substantive opposing views 

to this proposal.

The Exchanges certify that this submission has been concurrently posted on the Exchanges’ website at 

http://www.cmegroup.com/market-regulation/rule-filings.html.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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If you require any additional information regarding this submission, please contact the undersigned at 

212.299.2200 or via email at CMEGSubmissionInquiry@cmegroup.com.

Sincerely, 

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachment: Exhibit A: CME/CBOT/NYMEX/COMEX Hedge Exemption Form (blackline format)
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EXHIBIT A

CME/CBOT/NYMEX/COMEX Hedge Exemption Form

(additions underscored; deletions struck through)

(provided under separate cover)