SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-317

Organization: Chicago Mercantile Exchange Inc. ("CME")

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 FX 

Options Large Trade Discount 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 FX Options Large Trade Discount Program

CME Submission No. 23-317

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME” or “Exchange”) hereby notifies the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) of plans to modify the FX Options Large Trade Discount 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. 

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

Exchange Act (“CEA”). During the review, CME 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 CME 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 CME 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.

CME 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 CME Submission No. 23-317 in any related correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Enclosure: Exhibit 1
EXHIBIT 1

FX Options Large Trade Discount Program

Program Purpose

The purpose of this Program is to incentivize participants to build liquidity in foreign exchange options

products. More liquid contracts benefit all participants in the marketplace.

Product Scope

All FX options (“Products”). 

Eligible Participants

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

CME members or non-members. The incentives described below will be automatically applied to all 

applicable transactions in the Products. 

Program Term 

Start date is July 1, 2020. End date is July 31, 2023 July 31, 2024.

Hours

N/A

Incentives

Large Trade Discount: All market participants will receive a 75% fee discounts in accordance with the 

table below on ZAR, BRL, and MXN currency pairs and a 50% fee discount on all other currency pairs for

any single trade fill (excluding certain give-ups*) that is greater than or equal to the minimum quantity 

block threshold level for each of the Products. 

All FX Options

Excluding ZAR, MXN, & BRL ZAR, MXN, & BRL

Membership Type Block

Discount

Globex Large 

Trade Discount

Block 

Discount

Globex Large 

Trade Discount

Individual Members

Clearing Equity Member Firms

Rule 106.J Equity Member Firms & 

Rule 106.J Qualified Subsidiaries

Rule 106.I Member Firms & Rule 

106.I Qualified Affiliates

Rule 106.S Member Approved Funds

50% 30% 75% 75%

Rule 106.D Lessees

Rule 106.F Employees 30% 30% 75% 75%

Rule 106.R Electronic Corporate 

Member 30% 30% 75% 75%

Rule 106.H and 106.N Firms 30% 30% 75% 75%
Clearing Non-Equity Member Firms

International Incentive Program (IIP) 

Participants

International Volume Incentive 

Program (IVIP) Participants

30% 30% 75% 75%

Central Bank Incentive Program 

(CBIP) Participants

Latin American Fund Manager 

Incentive Program (FMIP) 

Participants

30% 30% 75% 75%

CTA/Hedge Fund Incentive Program 

Participants 30% 30% 75% 75%

Members Trading Outside of Division 30% 30% 75% 75%

Non-Members 30% 30% 75% 75%

*Block give-ups are eligible for the discount. Other give-ups, including give-ups on outrights, Globex 

spreads, and EOOs are not eligible. 

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 the requirements

of the Program.