CX Futures Exchange, L.P.

Rule Amendment Submission #2019-01

March 18, 2019

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 

rules appear 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 CX Independent Software Vendor Large Order Incentive Program

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

The Independent Software Vendor Large Order Incentive Program (ISVLOIP) provides that any 

Participants that are Independent Software Vendors (ISVs) and that (1) provide API connectivity

to Cantor Exchange, (2) have executed the Exchange’s Vendor Connectivity Agreement (VCA), 

(3) have had their API connection certified by the Exchange, and (4) transmit Qualifying Large 

Orders to the Exchange shall receive compensation from the Exchange.

Specifically, the program provides that the Exchange will pay each ISV that meets the 

requirements above $3,000 for having its API connection certified by the Exchange and will 

receive an additional $3,000 for each 1,000 Qualifying Large Orders transmitted. A 

Qualifying Large Order is any order for 1,000 or more contracts that is transmitted through 
the ISV’s software and successfully executed on the exchange.

The Exchange has considered whether the ISVLOIP complies with Exchange Rules and with 

the following Core Principles:

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.

This program complies with the cited Core Principles by encouraging ISVs to build functionality 

that facilitates the submission of large orders to the Exchange. Such functionality will enhance

liquidity in the market in a manner designed to promote fair and equitable trading and, by being

available to all Participants, does not impose any restraint of trade or undue burden on 

competition. This program will be available for a period of two years and may be renewed in the

discretion of the Exchange for an additional two-years. This program may be terminated with 

thirty (30) days’ advance notice to Participants.
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: March 18, 2019
Attachment A — Rule Amendment

CHAPTER XI

INCENTIVE PROGRAMS

XI-103. Independent Software Vendor Large Order Incentive Program (ISVLOIP)

This incentive program shall be available to any Participant that is an Independent Software 

Vendor and (1) provides API connectivity to Cantor Exchange, (2) has executed the Exchange’s 

Vendor Connectivity Agreement (VCA) and such agreement is currently in effect, (3) has had its 

API connection certified by the Exchange.

Incentive payments will consist of:

1. $3,000 for having its API connection certified by the Exchange, and 

2. an additional $3,000 for each 1,000 Qualifying Large Orders that are transmitted through 

the ISV’s software and successfully executed on the exchange.

A Qualifying Large Order is any order submitted by a Participant using the ISV’s connection to the 

Exchange that is for 1,000 or more contracts and is successfully matched for the total order size

with contra-side order(s).

This program shall be in effect for two years from its effective date and may be renewed in the

absolute discretion of the Exchange for another two years. The program may be terminated at any

time by the Exchange in its absolute discretion upon thirty (30) days’ notice.