SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 24-045

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): January 9, 2024 Filing Description: Modifications to the CME 

Commodity Trading Advisors/Hedge Fund Incentive 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: 
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

Timothy Elliott

Managing Director and Chief Regulatory Counsel

Legal Department

January 9, 2024

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 CME Commodity Trading Advisors/Hedge Fund Incentive Program 

CME Submission No. 24-045

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 Commodity Trading Advisors (“CTA”)/Hedge Fund 

Incentive Program (“Program”). The modifications to the Program will become effective on February 1, 2024.

Exhibit 1 sets forth the terms of the 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 incentivize manipulative trading or market abuse and does not impact the Exchange’s ability to 

perform its trade practice and market surveillance obligations under the CEA. The Exchange’s market regulation staff 

will monitor trading in the Program’s products to prevent manipulative trading and market abuse. The Program does 

not impact the Exchange’s order execution. Participants in the Program will be selected by the Exchange’s staff using

criteria as further stated in Exhibit 1. Chapter 4 of the Exchange rules includes prohibitions against fraudulent, noncompetitive, unfair or abusive practices. The Program is subject to these rules. 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. 24-045 in any related correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

CME CTA/HEDGE FUND INCENTIVE PROGRAM

Program Purpose

The purpose of this Program is to incentivize CTAs and hedge funds to trade FX products on the CME 

Globex® Platform (“Globex”). The resulting increase in central limit order book liquidity for FX products on 

the CME Globex® Platform benefits all participant segments in the market. 

Product Scope

All standard size FX futures and options contracts that are traded on the CME Globex® Platform and

submitted via CME ClearPort block transactions in FX options (“Products”).

Eligible Participants

There is no limit to the number of participants that may be selected for the Program. All approved CTAs

and their managed accounts including: individual, non-hedge funds, and hedge funds may participate. 

CTAs, their managed accounts of individuals, non-hedge funds, and hedge funds must meet the following 

criteria to qualify for the Program:

• Be a registered CTA or qualify for an exemption pursuant to CFTC Regulations 4.14(a)(4), 4.14(a)(5), 

4.14(a)(8)(i)(D), 4.14(a)(10), or 3.10(c)(3)(i),

• Complete a Program application and provide all required supporting documentation for each

managed individual, non-hedge fund, and/or hedge fund to be registered in the Program, including:

o A list of all managed accounts owned by individuals, non-hedge funds, and funds and 

the CME clearing member account(s) for each,

o Confirmation of an open and funded clearing account(s) for each account,

o A copy of the document pursuant to which the Fund grants the investment manager or 

CTA discretionary trading authority or control over its clearing account(s).

Program Term 

Start date is December 23, 2011. End date is January 31, 2024 January 31, 2025. 

Hours

The incentives will apply to all trades made in the Products by all participants regardless of the execution 

time. N/A 

Incentives

Upon meeting all obligations, as determined by the Exchange, participants may be eligible to receive 

predetermined incentives.

Fee Discounts: Once accepted into the Program, all participants will be eligible to receive progressive fee 

volume discounts for trades executed in standard-size FX futures and options on Globex and via CME 

ClearPort, excluding transactions via FX Link. New participants will receive the lower of $1.20 or the 

discounted rate based on their prior calendar quarter’s average daily volume (“ADV”) in all FX futures and 

options executed on Globex or submitted via CME ClearPort, inclusive of FX Link and standard, micro, 
and mini-sized contracts (“Qualifying Volume”). After new participants have been in the Program for one 

(1) full calendar quarter, the applicable rates charged will be based on each respective participant’s 

Qualifying Volume. Fee discounts will be based on the latest calendar quarterly Qualifying Volume, 

measured over the preceding three (3) month period, and the fee discounts set forth below will apply to 

standard-size FX futures and options in the next calendar quarter as follows:

Current Quarter Exchange

Fee Rate

Prior Quarter Qualifying 

Volume

(sides)

Futures &

Options: Globex, 

EFP, and EFR 

Transactions

Options:

Blocks

0 – 24 $1.60 $1.60

25 – 250 $1.20 $1.20

251 – 1,000 $1.00 $1.00

1,001 – 2,000 $0.90 $0.90

2,001 – 5,000 $0.80 $0.80

5,001 – 7,500 $0.70 $0.80

7,501 + $0.60 $0.80

FX Link Fee Discounts: All participants that trade standard-size futures via FX Link will receive a flat rate 

of $0.60 per contract side traded.

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 no longer meets the eligibility 

requirements of the Program.