Via Portal Submission June 26, 2023

 MGEX Submission No. 23-38 

Mr. Christopher Kirkpatrick

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

RE: Rule Certification Submission Pursuant to Regulation 40.6(a); Amendment

to MGEX Rules Chapter 21

Dear Mr. Kirkpatrick: 

Pursuant to Commodity Exchange Act (“CEAct”) Section 5c and Commodity Futures 

Trading Commission (“CFTC” or “Commission”) Regulation 40.6(a), the Minneapolis 

Grain Exchange, LLC (“MGEX” or “Exchange”) hereby certifies that the attached 

amendments to MGEX Rules regarding definition changes and Clearing Member 

deadline adjustments complies with the CEAct and CFTC Regulations. MGEX further 

certifies that the submission and pending changes to the MGEX Rules have been posted 

on the Exchange website at the following link: http://www.mgex.com/regulation.html. 

Overview of Rule Amendment

MGEX is proposing the following Rule amendments to properly reflect Bitnomial’s 

proposed option contract in the MGEX Rulebook Definitions as an option on the Deci 

Bitcoin contract rather than the full-size Bitcoin contract. Additionally, the Rule 

amendments remove a Clearing Member reporting requirement that is no longer required 

following the launch of the new MGEX clearing system. 

DCO Core Principles

In connection with adding the following Rule amendments, the Exchange has reviewed 

the core principles for DCOs (“DCO Core Principles”) and has determined that the 

amendments comply with the requirements of such principles. During the review, MGEX 

identified the following DCO Core Principles as potentially being impacted:

• DCO Core Principle D – Risk Management: Core Principle D requires DCOs to 

maintain the ability to manage risks associated with discharging the responsibilities 

of the DCO through the use of appropriate tools and procedures. The new MGEX 

clearing system has updated the tools MGEX utilizes to manage risks associated 

with discharging its responsibilities as a DCO to satisfy this core principle, which is 
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7159

mgex.com

reflected by the Rule changes below.

• DCO Core Principle L – Public Information: Core Principle L requires DCOs to 

provide market participants with sufficient information and to have clear and 

comprehensive rules and procedures. The amendment to these Rules will be 

incorporated into the Exchange’s Rules, which are posted publicly on the MGEX 

website in satisfaction of this core principle.

Pursuant to MGEX Bylaw 3.1., the MGEX Board of Directors unanimously approved the 

attached amendments to the MGEX Rules. There were no substantive opposing views 

expressed by the Board of Directors, nor is the Exchange aware of any substantive 

opposing views with respect to this filing. The attached amendments are to be effective 

when incorporated into MGEX’s Rules on its website, which will be at least 10 business 

days following the date of this submission. If there are any questions regarding this 

submission, please contact me at (612) 321-7159 or apilon@mgex.com. Thank you for 

your attention to this matter.

 

Sincerely, 

Amanda R. Pilon

Associate Corporate Counsel, MGEX Clearing
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7159

mgex.com

EXHIBIT A 

The following MGEX Rule is to be amended. Additions are underlined while 

deletions are marked through. 

CHAPTER 1

DEFINITIONS

BITNOMIAL EXCHANGE CONTRACTS: Any contract listed on the Bitnomial Exchange 

and approved to be cleared by MGEX. Presently, Tthe Bitnomial Bitcoin Futures Contract, 

Bitnomial Deci Bitcoin Futures Contract, and Bitnomial Deci Bitcoin Options Contract, 

each as described in Chapter 12 of Bitnomial Exchange rules.

CHAPTER 23

BITNOMIAL EXCHANGE CLEARING RULES

23.9. DEADLINES AND SUMMARY FINES.

The schedule of deadlines is subject to change at any time by the Exchange. The

Exchange has adopted the following schedule of reporting deadlines (all times shall 

conform to Central Time):

7:30 a.m. Reporting of gross positions

9:00 a.m. Settlement and margin payment

11:00 a.m. Trading directive for same day collateral pledges* 

Trading directive for same day collateral pledge

release* 

11:15 a.m. Weekly account position updates

11:30 a.m. Intraday variation payment

4:10 p.m. Unmatched trade adjustments

4:15 p.m. Last submission of trades

 Give-up execution 

4:20 p.m. Give-up

acceptance

4:30 p.m. Auto-Exercise Cancellations
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7159

mgex.com

Options position reports on expiration

day

5:10 p.m. Bitnomial delivery files

7:30 p.m. Customer gross margin files

*Submitting a Trading directive to the Exchange does not guarantee same day 

transfers of a security. MGEX is not responsible for delays caused by the 

inaccuracy or untimely submission of information by a Clearing Member required 

to facilitate the transfer of securities to or from MGEX’s safekeeping accounts.

Any unresolved unmatched trades may be suspended pending possible resolution the

following Business Day as an "as of" trade. "As of" trades can be carried no longer than 

one Business Day. Any “as of” trade which is subsequently given up must be done in 

accordance with Rule 2102.00. and the deadlines established in Resolution 2101.00.C.

In addition to the deadlines set forth above, the Exchange has adopted delivery specific 

deadlines (see Rule 23.12.4.).

Any deadline or submission listed herein that is missed, late, inaccurate or incomplete, 

may result in a summary fine or other disciplinary action, including but not limited to, the 

matter being referred to the Disciplinary Committee as determined by the Exchange.

Trading session submissions must be submitted accurately and in accordance with the 

deadlines set forth in this Rule. All submissions received after the respective deadlines 

are subject to a warning letter or fine. The schedule is as follows:

1st Offense: Warning Letter

2nd Offense: $1,000 fine

3rd Offense: $2,500 fine

4th Offense: $5,000 fine

The 5th offense and every subsequent offense will be referred to the Disciplinary 

Committee. Offenses and fines shall be based upon events occurring within a rolling 

twelve (12) month period. The Exchange may determine whether a warning letter or a 

fine is warranted based on the facts and circumstances, and may take further disciplinary 

action, increase the amount, or present the matter to the Disciplinary Committee. 

In the event a fine is imposed, the Exchange will issue a notice of the offense and fine 

amount to the offending party. Any fines must be paid within thirty (30) days of issuance

unless otherwise stated by the Exchange.
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7159

mgex.com

CHAPTER 72

RESOLUTIONS

RESOLUTION 2101.00.C. 

The Exchange has adopted the following schedule of reporting deadlines (all times listed 

shall conform to Central Time):

7:30 a.m. Reporting of gross positions

Exercise account updates 

9:00 a.m. Settlement and margin payment 

11:00 a.m. Trading directive for same day collateral pledges*

Trading directive for same day collateral pledge release* 

 11:15 a.m. Weekly account position updates

11:30 a.m. Intraday variation payment

4:10 p.m. Unmatched trade adjustments

4:15 p.m. Last submission of trades

Give-up execution

4:20 p.m. Give-up acceptance

4:30 p.m. Auto-Exercise Cancellation Notices 

 Options position reports on expiration day

SPK Futures position reports on expiration day

4:45 p.m. Long position lists for delivery (HRSW Futures) 

Delivery Notices 

Exercise Notices

 

5:10 p.m. SPK Futures delivery accounts updates

7:30 p.m. Customer gross margin files

*Submitting a Trading directive to the Exchange does not guarantee same day 

transfers of a security. MGEX is not responsible for delays caused by the 

inaccuracy or untimely submission of information by a Clearing Member required 

to facilitate the transfer of securities to or from MGEX’s safekeeping accounts. 

Trading activity after five o’clock (5:00) p.m. to four o’clock (4:00) p.m. the following day 

will be cleared with said following day’s trading activity. 
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7159

mgex.com

All trades must be submitted no later than four fifteen o’clock (4:15) p.m.

Any unresolved unmatched trades may be suspended pending possible resolution the 

following Business Day as an "as of" trade. "As of" trades can be carried no longer than 

one Business Day.

Pursuant to Rules 2.3.5. and 1227.00., any deadline or submission listed herein that is 

missed, late, inaccurate or incomplete, may result in a fine or the matter being referred to 

the Disciplinary Committee as determined by the Exchange.