SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-319

Organization: The Board of Trade of the City of Chicago, Inc. (“CBOT”)

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): July 14, 2023 Filing Description: Modifications to the Grain & 

Oilseed Futures ETH Market Maker Program

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: Not Applicable

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

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

July 14, 2023

VIA ELECTRONIC PORTAL

Christopher J. Kirkpatrick 

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Modifications to the Grain & Oilseed Futures ETH Market Maker Program

CBOT Submission No. 23-319

Dear Mr. Kirkpatrick:

The Board of Trade of the City of Chicago, Inc. (“CBOT” or “Exchange”) hereby notifies the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) of plans to modify the Grain & Oilseed Futures ETH Market Maker 

Program (“Program”). The modifications to the Program will become effective on August 1, 2023.

Exhibit 1 sets forth the terms of this Program. Modifications appear below, with additions underlined and deletions 

overstruck. 

CBOT reviewed the designated contract market core principles (“Core Principles”) as set forth in the Commodity

Exchange Act (“CEA”). During the review, CBOT staff identified the following Core Principles as potentially being 

impacted: Monitoring of Trading, Execution of Transactions, Protection of Market Participants, Compliance with 

Rules, Availability of General Information, and Recordkeeping

The Program does not impact the Exchange’s ability to perform its trade practice and market surveillance obligations 

under the CEA. Exchange staff will monitor trading in the Program’s products in order to prevent manipulative trading 

and market abuse. Additionally, the Exchange has implemented systems to track Program participants’ volume to 

ensure proper distribution of earned incentives. The Program does not impact the Exchange’s order execution. 

Participants in the Program will be selected by CBOT staff using criteria as set forth in Exhibit 1. Chapter 4 of the 

Exchange rules includes prohibitions against fraudulent, non-competitive, unfair or abusive practices. All participants 

must execute a contractual agreement with CBOT in which each participant will expressly agree to comply with, and 

be subject to, applicable regulations and Exchange rules. Additionally, the Program is subject to the Exchange’s 

record retention policies, which comply with the CEA.

CBOT certifies that the Program complies with the CEA and the regulations thereunder. There were no substantive 

opposing views to this Program.

The Exchange certifies that this submission has been concurrently posted on the Exchange’s website at 

http://www.cmegroup.com/market-regulation/rule-filings.html. 

If you require any additional information regarding this submission, please e-mail 

CMEGSubmissionInquiry@cmegroup.com or contact Rachel Johnson at 312-466-4393 or via e-mail at 

Rachel.Johnson@cmegroup.com. Please reference our CBOT Submission No. 23-319 in any related 

correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Enclosure: Exhibit 1
EXHIBIT 1

Grain & Oilseed Futures ETH Market Maker Program

Program Purpose

The purpose of this Program is to incentivize participants to increase overnight liquidity during Extended 

Trading Hours (“ETH”) in the products listed below. More liquid contracts on the central limit order book 

benefit all participants in the marketplace.

Product Scope

Corn Futures (“ZC”), Soybean Futures (“ZS”), Soybean Meal Futures (“ZM”), Soybean Oil Futures (“ZL”), 

KC HRW Wheat Futures (“KE”), and Chicago SRW Wheat Futures (“ZW”) traded on the CME Globex 

Platform (“Products”).

Eligible Participants

There is no limit to the number of participants that may participate in the Program. Participants must be 

proprietary trading firms. Participants may be CBOT members or non-members. 

Program Term 

Start date is January 1, 2017. End date is July 31, 2023 July 31, 2024.

Hours

ETH (7:00PM – 8:29:59AM 8:30AM CST).

Obligations

Minimum Quoting Obligations*: In order to be eligible to receive incentives, participants must quote 

continuous two-sided markets in designated contract months of the Products at maximum bid/ask 

spreads and minimum quote sizes in accordance with the baseline quoting obligations table below. 

Notwithstanding the foregoing, CBOT may vary the quoting obligations and/or the time-in-market as it 

deems necessary based on ongoing evaluations of the Program. 

ZC, ZS ZM, ZL, KE, ZW

Maximum 

Bid/Ask 

Spread

Minimum 

Quote Size

Maximum 

Bid/Ask 

Spread

Minimum 

Quote Size

Time-in-Market 

(ETH: 7:00PM –

8:29:59AM

7:45AM, clear by 

8:30AM CST)

2

nd & 3rd Months 5 8 6 4 70%

4

th + Months 7 8 8 4 70%
*The first contract month is defined as the nearby contract that can still be traded on Globex unless it is in 

its delivery month, at which point the next contract will be named the “Lead Month.” The second contract 

is the month following the Lead Month, and so on. 

Extreme Events Clause: If the at-the-money (“ATM”) implied volatility exceeds the values in Table A for 

two (2) consecutive trading days for three (3) out of six (6) of the Products, the obligations in Table B may 

be implemented. Participants will be given notice that the Extreme Events Clause has taken effect.

(i) Table A

Product

30-Day Constant 

Maturity (ATM Implied 

Volatility)

ZC 35%

ZS 28%

ZW 35%

KE 35%

ZL 35%

ZM 30%

(ii) Table B

ZC, ZS ZM, ZL, KE, ZW

Maximum 

Bid/Ask 

Spread

Minimum 

Quote Size

Maximum 

Bid/Ask 

Spread

Minimum 

Quote Size

Time-in-Market 

(ETH: 7:00PM –

8:29:59AM

7:45AM, clear by 

8:30AM CST)

2

nd & 3rd Months 6 5 8 3 70%

4

th + Months 9 5 11 3 70%

Once the Extreme Events Clause is in effect, if ATM implied volatility is less than the levels in Table A 

during the two (2) consecutive days prior to expiration, the Minimum Quoting Obligations will be 

reinstated. If the ATM volatility exceeds the levels in Table A, the Extreme Events Clause obligations will 

continue for the next full month.

Notwithstanding the foregoing, the Exchange may further reduce the bid/ask spreads, sizes, or time-inmarket obligations based on ongoing evaluations of market conditions and volatility. Participants will be 

given notice that the Extreme Events Clause has taken effect.

Holiday Quoting Schedule: There will be no quoting obligations on the dates listed below. The Holiday 

Quoting Schedule may be adjusted by the Exchange. Participants will be given notice of any adjustments 

to the Holiday Quoting Schedule.

Date Name of Holiday

9/5/2022 Labor Day

11/24/2022 Thanksgiving

12/26/2022 Christmas (Observed)

1/2/2023 New Year’s (Observed)

1/16/2023 Birthday of Dr. Martin Luther King, Jr.

2/20/2023 Presidents’ Day

4/7/2023 Good Friday

5/29/2023 Memorial Day
6/19/2023 Juneteenth

7/4/2023 Independence Day

9/4/2023 Labor Day

11/23/2023 Thanksgiving

12/25/2023 Christmas

12/26/2023 Post-Christmas

1/1/2024 New Year’s

1/2/2024 Post-New Year’s

1/15/2024 Birthday of Dr. Martin Luther King, Jr.

2/19/2024 Presidents’ Day

3/29/2024 Good Friday

5/27/2024 Memorial Day

6/19/2024 Juneteenth

6/20/2024 Post-Juneteenth

7/4/2024 Independence Day

Incentives

Passive Volume Credits: Upon meeting all obligations, as determined by the Exchange, participants will 

be eligible to receive Passive Volume Credits. Participant’s volume will receive the applicable credit 

multipliers set forth in the table below. Each leg of a spread will count as a separate trade. Each month, a 

participant’s Passive Volume Credits will be calculated and multiplied by $0.20. Passive Volume Credits 

will be capped at $5,000 per month, per participant for each of the following products: ZC, KE, and ZW. 

Passive Volume Credits for ZS, ZM, and ZL will be capped per month, per participant as follows: (i) 

$8,500 for meeting obligations in one (1) product, (ii) $10,000 for meeting obligations in two (2) products, 

or (iii) $12,500 for meeting obligations in all three (3) products.

Passive Volume Credits

Contract Month Credit Multiplier

1 n/a

2 2

3 3

4 4

5 5

6 6

7 7

8+ 8

Monitoring and Termination of Status

The Exchange shall monitor trading activity and participants’ performance and shall retain the right to 

revoke participant status if it concludes from review that a participant has failed to meet its obligations or 

no longer meets the eligibility requirements of the Program. 

If the Exchange determines that a participant has not met its quoting obligations during two (2) calendar 

months over the course of the Program, but is within twenty percent (20%) of the time-in-market 

obligations, the participant will be eligible to receive the incentives for each applicable month.

If the Exchange determines that a participant has not met its quoting obligations during one (1) additional 

calendar month, the participant will be eligible to receive all incentives for that applicable month. 
Participants must meet quoting obligations for all subsequent months in order to continue to receive the

incentives.

Upon utilizing the exceptions set forth above, participants that fail to meet quoting obligations in any 

additional month may be removed from the Program.