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CX Futures Exchange, L.P.

Rule Amendment Submission #2018-03

June 28, 2018

1. The text of the rule changes to the CX Futures Exchange L.P. (“Exchange” or “CX”) 

Rulebook is attached. Additions are underlined and deletions are stricken through. This rule has 

been approved by the Exchange. Capitalized terms, unless otherwise defined herein shall 

possess the meaning(s) ascribed in Exchange Rulebook.

2. The proposed effective date is ten business days after receipt by the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) of this submission. 

3. Attached, please find a certification that: (1) these rules comply with the Commodity 

Exchange Act and the Commission’s regulations thereunder; and (2) concurrent with this 

submission, CX Futures Exchange, L.P. posted on its website: (i) a notice of pending 

certification of the rule submissions with the Commission; and (ii) a copy of this submission.

4. A concise explanation and analysis of the operation, purpose, and effect of the amended 

rule appears below.

5. There were no opposing views expressed regarding these amended rules.

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CONCISE EXPLANATION AND ANALYSIS OF THE OPERATION, PURPOSE, AND 

EFFECT OF THE CERTIFIED RULE AND ITS COMPLIANCE WITH APPLICABLE 

PROVISIONS OF THE ACT, INCLUDING CORE PRINCIPLES AND THE COMMISSION’S 

REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.6(a)(7)(vi), the following is a concise explanation and analysis 

of the operation, purpose, and effect of the amended rules.

Description of TradeWx Incentive Program (TIP)

This program is being submitted for self-certification as an incentive program of the Exchange. 

The TradeWx Incentive Program is for Exchange Participants that as prospective participants

earned credits by participating in an educational module that simulates trading on the Exchange. 

Persons may also participate solely in the educational module without participating in, or 

qualifying for, the incentive program. Persons choosing to participate solely in the educational 

module, or who are not eligible to become a Participant on the Exchange, are not eligible to 

participate in the incentive payments.

The simulation, as an educational tool, may incorporate certain aspects of CX’s weather 

contracts, however the simulation environment is in all ways separate from the Exchange’s 

production environment and is operated apart from the functionality of the trading environment.
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Specifically, the simulation consists of an interactive weather prediction website, sponsored by 

the Exchange, that simulates trading and enables prospective participants to earn credits (1) for 

registering, (2) by logging in at least once daily, (3) by correctly forecasting if certain weather 

events will or will not occur, and (4) other tasks which are intended to acquaint participants with 

trading mechanics. 

The simulation may be accessed by visiting http://forecasterchallenge.accuweather.com or other 

URLs as made available from time to time (the “Sites”). Prior to and during the simulation 

program, visitors to the Sites will be presented with an opportunity to predict different weather 

outcomes (e.g. daily and monthly snow amount, daily and monthly rain amount, daily high and 

low temperature, hurricane landfall locations, etc.) for a variety of locations in the continental 

United States.

Nothing in the operation of the simulation in any way affects the applicability of the Exchange’s 

requirements or eligibility standards to become a Participant of the Exchange. 

Simulation credits may be earned at any time and are accumulated through participation in the 

educational module. Simulation credits are not valid U.S. currency, have no value on the 

Exchange, have no cash value, and are used for purely educational purposes. 

Simulation credits earned by participation in the educational module may be converted by 

Exchange Participants to an incentive payment in U.S. dollars at conversion rates to be 

established by the Exchange and posted on the Exchange website from time to time. Each 

Exchange Participant will be subject to a maximum conversion equivalent of $10 in any one 

calendar day and a maximum per Participant total conversion equivalent of $100. Furthermore, 

the total amount of simulation credits that may be converted will be subject to an aggregate

monthly cap. A prospective Participant must apply to become and be accepted as a CX 

Participant in order to access the incentive funds that have been credited to his or her account. 

Incentive funds credited to a CX Participant’s account under this program may be withdrawn 

beginning on October 1, 2018.

The initial phase of the cash incentive program will permit conversions of points to $10 U.S. 

dollars starting on August 1, 2018 at 9:00:00 AM Eastern Time (“ET”), and this phase will end 

on August 31, 2018 at 5:00:00 PM ET (“August Program Period”). Subsequent monthly 

program periods are anticipated and will be announced. Conversion rates for each monthly 

program will be posted on the Exchange website. The August Program Period will cap aggregate 

conversions during that period for all program participants at $5,000.

The rules governing the TradeWx Incentive Program are attached as Attachment A. 

As incentive payment conversions are requested, CX will deposit the corresponding U.S. dollar 

amount directly into the Participant’s CX Clearinghouse account. These funds may thereafter be 

withdrawn by Participants. There is no Exchange trading requirement to access, withdraw, or 
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otherwise utilize these funds. However, simulation participants must apply to become and be 

accepted as a CX Participant in order to receive and view their incentive payments. 

Because the program is meant as an educational tool, the Exchange will monitor activity on the 

Site for compliance with Exchange rules (“Rules”) and advise persons utilizing the simulation as 

to the appropriate conduct for trading. Any activity that, in the sole discretion of the Exchange, is 

in violation of the Rules or of the rules of the simulation play or of the program will void credits 

earned, terminate simulation access, negate conversion of credits to incentive payments, deny 

access to CX as a Participant and/or be subject to other actions by the Exchange. No other 

penalties shall apply for violation of the Rules or the rules of the promotion relating to activity in 

the simulation.

The simulation is available to persons that may not qualify for, or may be restricted from, 

becoming a Participant of the Exchange, including Exchange employees. However, payment of 

the cash incentive is exclusively available to Exchange Participants and is not available to 

persons that are not eligible to become a CX Participant. 

The Exchange intends to review the effectiveness of the program within 2 years from the start of 

the program.

As the Sites utilize a technology infrastructure distinct from the one used by the Exchange for 

actual trading, the simulation will in no way affect trading on the Exchange. And thus, the 

promotion will not in any way affect the Exchange’s ability to adhere to its requirements under 

the Core Principles or Commission regulations. Nothing in the incentive program, which is 

intended to encourage Participants to become better educated and more knowledgeable traders, 

will in any way adversely affect the Exchange’s ability to adhere to the Core Principles or 

Commission regulations thereunder, including: 

a) Core Principle 9: to provide a competitive, open, and efficient market for execution; 

b) Core Principle 12: to establish and enforce rules to protect markets and market 

participants from abusive practices and to promote fair and equitable trading on designated 

contract markets; and 

c) Core Principle 19: to avoid adopting any rules or taking any actions that result in 

unreasonable restraints of trade. 
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CERTIFICATIONS PURSUANT TO SECTION 5c OF THE COMMODITY EXCHANGE

ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE 40.6, 

17 C.F.R. §40.6

I hereby certify that:

(1) the amended Rules below comply with the Commodity Exchange Act, and the 

Commodity Futures Trading Commission’s regulations thereunder; and

(2) concurrent with this submission, CX Futures Exchange, L.P. posted on its 

website: (a) a notice of pending certification of the above Rules with the 

Commission; and (b) a copy of this submission. 

_________________________

By: Nolan Glantz

Title: COO

Date: June 28, 2018
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Attachment A — Rule Amendment

CHAPTER XI

INCENTIVE PROGRAMS

XI-100. TradeWx Incentive Program (TIP)

Purpose of Incentive Program:

The object of the TradeWx Incentive Program (“TIP” or “Program”) is to familiarize Exchange 

Participants with the basic concepts and website functionality needed to trade “Swap Contracts” 

on CX Futures Exchange, L.P. (“Exchange” or “CX”). The Program consists of providing 

payments to Exchange Participants for participating in an educational module that operates on an 

interactive weather prediction website. The educational module enables its users to earn 

“credits” by correctly forecasting if certain weather events will or will not occur. Such credits 

may be converted by Exchange Participants into incentive payments. Persons not eligible to be 

an Exchange Participant may also participate in the educational module operated on the 

interactive weather prediction website solely for its educational value. 

Eligibility:

The TradeWx Incentive Program (“TIP”) is open to legal residents of the 50 United States and 

the District of Columbia, who at time of registration are Participants of the Exchange or who are 

eligible to become a Participant of the Exchange (“Program Participant”). There is no cost to 

apply as a Program Participant. There is no trading or other obligation on a Program Participant 

to redeem any cash incentives provided by this program. Persons not eligible to become a 

Program Participant or who do not wish to participate in the Incentive Program may participate 

on the interactive weather prediction website solely for its educational value, becoming a “

Simulation User.”

Becoming a Simulation User, as defined below, does not indicate that any person qualifies to 

become a Participant of the Exchange. Incentive Program Participants must be or become a CX 

Participant, in accordance with Rule III-3 (Eligibility) of the Exchange Rules. Simulation Users

may apply to become Exchange Participants and to set up a CX Trading Account at the 

Exchange website at any time before or during the TIP Period. Applicants to become an 

Exchange Participant who submit a completed Application and are accepted for a CX Trading 

Account will be notified by email. Anyone who needs to modify or correct an email address 

used in either their TradeWx or CX Trading Account should contact the Exchange at 

customerservice@cantorexchange.com. Incentive Program Participants will receive incentive 

payments directly in their CX Clearinghouse Account. Program Participants are not required to 

trade on the Exchange and may withdraw incentive funds from their CX Clearinghouse Account

beginning on October 1, 2018 at 9:00 AM ET, which payments are made by the Clearinghouse

via electronic transfer to a U.S. bank account. 
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There is a limit of one (1) TradeWx Incentive Program participation per CX Participant

for the duration of the TIP. Simulation Users may register for only simulation account. 

Simulation Users who register for more than one (1) simulation account may lose credit 

balances in one or all of the simulation accounts they control as determined by the 

Exchange.

Simulation Summary:

Simulation Users visiting forecasterchallenge.accuweather.com or other URLs provided via the 

Exchange website (the “Sites”) will be presented with an opportunity to earn credits for 

registering, visiting and/or predicting weather outcomes (e.g. daily and monthly snow amount, 

daily and monthly rain amount, daily high and low temperature) for a variety of locations in the 

continental United States.

Following registration, Simulation Users will be given the option to practice trading situations by 

making numerous weather forecasts using their simulation credit balances. All credits used to 

make a prediction are immediately deducted from the Simulation User’s account but will result 

in the Simulation User earning a greater number of credits if the forecasted weather event occurs. 

Correct trading decisions/forecasts will result in credits being credited to the Simulation User’s 

account as soon as practical after the Exchange’s final determination that the forecasted weather 

event has occurred. 

The Exchange may offer additional credit bonuses for simulation play elements other than 

making weather predictions. Specifically, upon registering on the Site with a valid email address, 

each Simulation User will receive a total of 25,000 simulation credits in their account. Additional 

credits can be obtained each day the Participant visits any of the Sites. Other opportunities to 

earn credits apart from making weather predictions may, from time to time, be presented to 

Users.

The Exchange will have exclusive right to determine if a weather event has or has not occurred 

in consultation with the Weather Data Provider.

The Incentive Program - Converting Credits to U.S. Dollars:

Simulation credits are not valid U.S. currency, have no cash value and are used for simulation

purposes only on the Sites.

However, from time to time, Users who are or who are eligible to become Participants will be 

offered the option of converting credits in their simulation account for $10 cash, which amount 

will be deposited by the Exchange into a valid CX Clearinghouse Account as described below.

No one Participant may receive more than $10 per calendar day or more than $100 in the 

aggregate under this Incentive Program. Exchange, in its sole discretion, will determine credit 

tabulations and forecast winners during the TIP Period.
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Furthermore, the total amount of conversions that will be permitted in any one calendar month 

will be published on the Exchange website. The conversion of credits to U.S. dollars will be 

prioritized by time of request. In event that the aggregate of Simulation User conversion requests 

exceeds the monthly cap, then conversions shall be awarded by order of first conversion request.

Credits that are not converted due to the monthly cap will be returned to Simulation Users and 

may be converted in subsequent months. For the avoidance of doubt, if the number of conversion 

request is less than the monthly cap, then the Exchange will award less than the monthly cap to 

Program Participants for that monthly TIP Period. 

There is no financial obligation required to obtain a valid CX Trading Account, however 

Program Participants are required to complete fully and submit the CX Participant Application 

Packet (“Application”) according to the instructions provided. To comply with regulatory 

requirements, valid CX Trading Accounts require the Program Participant’s Social Security 

Number on the Application along with all other required fields in accordance with the 

instructions provided. Social Security Number and other required Program Participant

information to be used for Application processing and solely for the purpose of administering 

this Program and the Participant’s CX Trading Account.

All federal, state and local taxes, and all other expenses associated with Simulation User 

conversions are Simulation User’s sole responsibility. Participants will receive their converted 

amounts as deposits to the CX Participant Clearinghouse Accounts within one week of the 

completion of the verification process. In the event that a conversion requested was rejected for 

any reason, the Simulation User’s simulation account balance will be re-credited with the credit 

conversion amount.

Limit one (1) Application per person. Additional Applications received from any one 

person or email address after the first Application received from that person or email 

address will void all related simulation accounts and credit balances. 

The decision to accept or reject an Application to become an Exchange Participant or a 

Simulation User is at the sole discretion of Exchange. Incomplete Applications and/or 

Applications containing inaccurate information will be void at Exchange’s sole discretion. 

Completed Applications are subject to review and approval by Exchange. The use of script, 

macro or any device to automate or subvert the Application and/or participation process is 

prohibited and all such Applications will be void.

Compliance with CX Trading Rules:

The Exchange will monitor all Simulation User activity for compliance with Exchange rules and 

regulations (“Rules”), available at the Exchange website and incorporated herein by reference as 

a rule of the simulation play. Any credits acquired through activity that, in the sole discretion of 

Exchange, is in violation of the Rules in this section or any Exchange Rule will be deemed void

and may result in forfeiture of all credits earned by the Simulation User or denying Simulation 
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User access to the Sites. Accordingly, the Exchange reserves the right, in its sole discretion, to 

void any and all credits or other activities of any Simulation User whom Exchange believes has 

attempted to tamper with, influence or impair the administration, security, fairness, or proper 

play of this simulation module.

CX Released Parties and AW Released Parties (as those terms are defined below) are not 

responsible for incomplete, inaccurate, garbled, late, lost, stolen, damaged, undelivered, delayed, 

or misdirected emails, Applications, or TradeWx submissions; theft, destruction or unauthorized 

access to, or alteration of, Applications or TradeWx activity; credit allocation errors; failures or 

malfunctions of phones, phone lines or telephone systems; interrupted or unavailable network,

cable, satellite, Internet Service Provider (ISP), server or other connections; any error, omission, 

interruption, defect or delay in any transmission or communication; traffic congestion on the 

Internet or for any technical problem, including but not limited to any injury or damage to

Simulation User’s or any other person’s computer related to or resulting from participation in 

this simulation module; typographical or errors in these Rules, in any Program-related 

advertisements or other materials; the cancellation, suspension or preemption of any trading 

activity, trading activity tabulation or other problems or errors of any kind, whether mechanical, 

human, electronic, typographical, printing or otherwise, which may occur in connection with the 

administration of this simulation game, the tabulation of profits and/or credits, or the 

announcement of the winners. Credits which are incorrectly or improperly allocated to a 

simulation account are void and will be forfeited.

CAUTION: Any Simulation User attempt to deliberately damage the website or undermine 

the legitimate operation of this program is a violation of criminal and civil laws and should 

such an attempt be made, the Exchange reserves the right to seek damages and/or other 

remedies (including attorneys’ fees) from any such person(s) responsible for the attempt to 

the fullest extent permitted by law.

TIP Period:

A new TIP will begin each month (each a “TIP Period”). Each monthly TIP Period will be listed 

on the CX website. Exchange’s servers are the official time clock. The Exchange, in its sole 

discretion, may choose to discontinue offering new TIP Periods.

Conflicts of Interests

Employees, officers, directors, and representatives of CX Futures Exchange, L.P., and its 

respective parent company, subsidiaries, affiliates, distributors, and advertising/promotion 

agencies (collectively, “CX Released Parties”) and their immediate family members (parent, 

spouse, sibling or child and their respective spouses, regardless of where they reside) and those 

living in the same household of each, whether or not related, may be Simulation Users but are 

not eligible Program Participants and therefore may not request the conversion of simulation 

credits to U.S. dollars. 
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Furthermore, employees, officers, directors, and representatives of AccuWeather, Inc. (“Weather 

Data Provider”), and its respective parent company, subsidiaries, affiliates, distributors, and 

advertising/promotion agencies (collectively, “AW Released Parties”) and their immediate 

family members (parent, spouse, sibling or child and their respective spouses, regardless of 

where they reside) and those living in the same household of each, whether or not related, may 

be Simulation Users but may not request the conversion of simulation credits to U.S. dollars.

Miscellaneous: 

No transfer, assignment, cash conversion, or substitution of credits except by Exchange, which 

reserves the right to substitute a credit or cash conversion amount with one of comparable or 

greater value, at its sole discretion. Exchange, in its sole discretion, reserves the right to modify, 

suspend or terminate this Program for any reason, including should any virus, bugs, nonauthorized human intervention or other causes, corrupt or impair the administration, security, 

fairness or proper play of this Program.

By participating, Participants agree to be bound by these Rules and agree that CX and its 

designees and assigns may use (unless prohibited by law) such Participant’s name, city, and/or 

state of residence, photograph and/or likeness for advertising and/or trade purposes and/or for the 

purpose of posting their name, user name and/or for any other purpose in any media or format 

now or hereafter known throughout the world in perpetuity without further compensation, 

permission or notification; and shall have no liability and will be held harmless for any liability, 

loss, injury or damage, including, without limitation, personal injury to Participant or any other 

person or death or damage to personal or real property, due in whole or in part, directly or 

indirectly, by reason of the acceptance, possession, use or misuse of any credits or cash 

conversion amount related thereto or participation in this Program.