433 West Van Buren Street › Suite 700S › Chicago, IL 60607 › cboe.com

November 1, 2023

Christopher J. Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Cboe Futures Exchange, LLC Rule Certification

Submission Number CFE-2023-023

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and 

Regulation 40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission 

(“CFTC” or “Commission”) under the Act, Cboe Futures Exchange, LLC (“CFE” or “Exchange”) 

hereby submits a CFE rule amendment (“Amendment”) to extend and amend the Lead Market 

Maker Program (“LMM Program”) for Options on Cboe® iBoxx® iShares® $ Investment Grade

Corporate Bond Index Futures (“IBGO options”). The Amendment is set forth in a segregated 

confidential Appendix A to this submission. The Amendment will become effective on January 1, 

2024.

Any CFE Trading Privilege Holder (“TPH”) organization may apply to the Exchange for 

appointment as a lead market maker (“LMM”) under the amended LMM Program. Each LMM 

application, LMM appointment, and LMM under the amended LMM Program is specific to a TPH 

and to one of that TPH’s Executing Firm IDs (“EFIDs”) referred to as an “LMM Program EFID”. 

Accordingly, a TPH may apply for and receive more than one LMM appointment under the 

amended LMM Program, each of which is applicable to that TPH and to a different LMM Program 

EFID of that TPH. In that case, each of those LMMs is separately subject to the provisions of the 

amended LMM Program, including the market performance benchmark and benefit provisions of 

the amended LMM Program, as a single LMM.

The Exchange may appoint up to three LMMs for IBGO options under the amended LMM 

Program. LMMs are selected by the Exchange under the amended LMM Program based on the 

Exchange’s judgment as to which applicants are most qualified to perform the functions of an LMM 

for IBGO options based on specified criteria.

The amended LMM Program provides for market performance benchmarks that LMMs

must satisfy in order to receive specified benefits. The market performance benchmarks include

parameters with respect to minimum two-sided quote size and maximum quote width. The market 

performance benchmarks are applicable during IBGO options trading hours. The benefits under 

the amended LMM Program are intended to attract and retain liquidity providers in IBGO options. 

Exhibit 1 to this submission includes the description of the amended LMM Program which CFE 

will include in Policy and Procedure II of the Policies and Procedures Section of the CFE 
2

Rulebook.1

 The Exchange believes that the market performance benchmarks and associated

benefits under the amended LMM Program strike the appropriate balance to incentivize and retain 

liquidity providers in IBGO options.

The amended LMM Program expires on December 31, 2024, unless the amended LMM 

Program is extended by the Exchange. CFE may determine to extend the term of the amended 

LMM Program and LMM appointments under the amended LMM Program, allow the amended 

LMM Program and LMM appointments under the amended LMM Program to expire, terminate the 

amended LMM Program and all LMM appointments under the amended LMM Program at any 

time, or amend or replace the amended LMM Program with a different market maker program at 

any time. Any of these actions, other than allowing the amended LMM Program to expire, would 

be done through a subsequent rule amendment submission to the Commission.

CFE believes that the Amendment is consistent with the Designated Contract Market 

(“DCM”) Core Principles under Section 5 of the Act. In particular, CFE believes that the 

Amendment is consistent with DCM Core Principles 2 (Compliance with Rules), 4 (Prevention of 

Market Disruption), 9 (Execution of Transactions), and 12 (Protection of Markets and Market 

Participants). CFE notes in this regard that: Each LMM in the amended LMM Program is obligated 

by CFE Rule 308 (Consent to Exchange Jurisdiction) to comply with Exchange rules. Each LMM

is also required under the terms of the amended LMM Program to utilize Exchange match trade 

prevention functionality under CFE Rule 406B (Match Trade Prevention) with respect to trading 

in IBGO options through its LMM Program EFID. Exchange rules include prohibitions against 

fraudulent, non-competitive, unfair, and abusive trading practices, and the Exchange will monitor 

trading in IBGO options for violative activity such as wash trading, manipulative trading, and 

market abuse. The Exchange believes that the amended LMM Program will have a positive impact 

on the price discovery process by fostering improved liquidity, market width and size, and trading 

volume in IBGO options traded on CFE’s centralized market and by incentivizing market 

participants to devote their efforts to enhancing market quality in IBGO options. Enhanced market 

quality benefits all participants in the IBGO options market. Accordingly, CFE believes that the 

impact of the Amendment will be beneficial to the public and market participants.

CFE is not aware of any substantive opposing views to the Amendment. CFE hereby 

certifies that the Amendment complies with the Act and the regulations thereunder. CFE further 

certifies that it has posted a notice of pending certification with the Commission and a copy of this 

submission on CFE’s website (http://www.cboe.com/us/futures/regulation/rule_filings/cfe/) 

concurrent with the filing of this submission with the Commission.

Questions regarding this submission may be directed to Arthur Reinstein at (312) 786-7570

or Shane Wilkerson at (484) 798-9350. Please reference our submission number CFE-2023-023

1 See Exhibit 2 for disclaimers and trademarks with respect to IBGO options relating to and of 

Markit Indices Limited and BlackRock Fund Advisors.
3

in any related correspondence.

Cboe Futures Exchange, LLC

/s/ Laura Fuson

By: Laura Fuson

Managing Director
4

EXHIBIT 1

(Additions are shown in underlined text and

deletions are shown in stricken text)

Cboe Futures Exchange, LLC

Policies and Procedures Section of Rulebook

* * * * *

II. Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index 

Futures Lead Market Maker Program

The Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index Futures 

Lead Market Maker Program (“Program”) is applicable with respect to IBGO options on futures 

(“IBGO options”).

Trading Privilege Holder (“TPH”) organizations may apply to the Exchange for 

appointment as a lead market maker (“LMM”) under the Program. Each LMM application, LMM 

appointment, and LMM under the Program is specific to a TPH and to one of that TPH’s Executing 

Firm IDs (“EFIDs”) referred to as an “LMM Program EFID”.

Accordingly, a TPH may apply for and receive more than one LMM appointment under 

the Program, each of which is applicable to that TPH and to a different LMM Program EFID of 

that TPH. In that case, each of those LMMs is separately subject to the provisions of the Program, 

including the market performance benchmark and benefit provisions of the Program, as a single 

LMM.

The Exchange may appoint up to two three LMMs under the Program. Any TPH that 

desires to apply for LMM status under the Program should submit an application in a form and 

manner prescribed by the Exchange.

LMMs shall be selected by the Exchange based on the Exchange’s judgment as to which 

applicants are most qualified to perform the functions of an LMM under the Program. Factors to 

be considered in making this selection may include, but are not limited to, satisfaction of the 

qualifications listed below as well as any one or more of the factors listed in Rule 515(b), as applied 

to LMM applicants instead of with respect to DPM applicants.

The following describes the qualifications, requirements, market performance benchmarks, 

benefits, and appointment term under the Program unless otherwise specified.

Qualifications

• Ability to automatically and systematically provide two-sided markets for IBGO options.

Requirements

• Each LMM shall designate in advance to the Exchange an LMM Program EFID. An LMM 

Program EFID is a single EFID through which the LMM will provide Orders to satisfy the 

market performance benchmarks under the Program. The LMM Program EFID designated 

by an LMM must be an EFID assigned to that TPH and may not be an EFID of another 
5

TPH. An LMM shall inform the Exchange in advance if the LMM determines to change 

its LMM Program EFID.

• Each LMM is required to utilize Exchange match trade prevention functionality under Rule 

406B with respect to trading in IBGO options through its LMM Program EFID.

Market Performance Benchmarks

• Each LMM shall provide Orders in IBGO options in conformity with specified criteria 

relating to minimum two-sided quote size and maximum quote width in order to receive 

specified benefits. These criteria apply during IBGO options trading hours.

• The Exchange may terminate, place conditions upon or otherwise limit a TPH’s 

appointment as an LMM under the Program if the TPH fails to satisfy the market 

performance benchmarks under the Program. However, failure of a TPH to satisfy the 

market performance benchmarks under the Program shall not be deemed a violation of 

Exchange rules.

Benefits

• An LMM is eligible to receive specified benefits in connection with acting as an LMM 

under the Program.

Term

• The Program and each LMM appointment under the Program will expire on December 31, 

2023 2024. The Exchange may determine to extend the term of the Program and LMM 

appointments under the Program, allow the Program and LMM appointments under the 

Program to expire, terminate the Program and all LMM appointments under the Program 

at any time or amend or replace the Program with a different market maker program at any 

time.

* * * * *
6

EXHIBIT 2

The iBoxx iShares $ High Yield Corporate Bond Index and the iBoxx iShares $ Investment Grade Corporate 

Bond Index (“iBoxx iShares $ Corporate Bond Indices”) are products of S&P Dow Jones Indices LLC or its 

affiliates or licensors (“S&P DJI”) and have been licensed for use by Cboe Exchange, Inc. iBoxx®, S&P®, “S&P 

500® and “Dividend Aristocrats® are registered trademarks of Standard & Poor’s Financial Services LLC 

(“S&P”); Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”) and 

has been licensed for use by S&P Dow Jones Indices; and these trademarks have been licensed for use by S&P 

DJI and sublicensed for certain purposes by Cboe Exchange, Inc. Cboe® iBoxx® iShares® $ High Yield 

Corporate Bond Index futures and options on futures and Cboe® iBoxx® iShares® $ Investment Grade Corporate 

Bond Index futures and options on futures are not sponsored, endorsed, sold or promoted by S&P DJI, Dow 

Jones, S&P, their respective affiliates, and none of such parties make any representation regarding the 

advisability of investing in such product(s) nor do they have any liability for any errors, omissions, or 

interruptions of the iBoxx iShares $ Corporate Bond Indices.

The iBoxx® iShares® $ High Yield Corporate Bond Index and the iBoxx® iShares® $ Investment Grade 

Corporate Bond Index (the “Indexes”), futures contracts on the Indexes and options on futures contracts on the 

Indexes (“Contracts”) are not sponsored by, or sold by BlackRock, Inc. or any of its affiliates (collectively, 

“BlackRock”). BlackRock makes no representation or warranty, express or implied to any person regarding the 

advisability of investing in securities, generally, or in the Contracts in particular. Nor does BlackRock make 

any representation or warranty as to the ability of the Index to track the performance of the fixed income 

securities market, generally, or the performance of HYG, LQD or any subset of fixed income securities.

BlackRock has not calculated, composed or determined the constituents or weightings of the fixed income 

securities that comprise the Indexes (“Underlying Data”). BlackRock is not responsible for and has not 

participated in the determination of the prices and amounts of the Contracts, or the timing of the issuance or 

sale of such Contracts or in the determination or calculation of the equation by which the Contracts are to be 

converted into cash (if applicable). BlackRock has no obligation or liability in connection with the 

administration or trading of the Contracts. BlackRock does not guarantee the accuracy or the completeness of 

the Underlying Data and any data included therein and BlackRock shall have no liability for any errors, 

omissions or interruptions related thereto.

BlackRock makes no warranty, express or implied, as to results to be obtained by S&P DJI, the parties to the 

Contracts or any other person with respect to the use of the Underlying Data or any data included therein. 

BlackRock makes no express or implied warranties and expressly disclaims all warranties of merchantability 

or fitness for a particular purpose or use with respect to the Underlying Data or any data included therein. 

Without limiting any of the foregoing, in no event shall BlackRock have any liability for any special, punitive, 

direct, indirect or consequential damages (including lost profits) resulting from the use of the Underlying Data 

or any data included therein, even if notified of the possibility of such damages.

iShares® is a registered trademark of BlackRock Fund Advisors and its affiliates.