SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-406

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): September 12, 2023 Filing Description: Modifications to the 

CME FX Link 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

September 12, 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 CME FX Link Market Maker Program

CME Submission No. 23-406

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 CME FX Link Market Maker Program (“Program”). The 

modifications to the Program will become effective on October 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. 23-406 in any related correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Enclosure: Exhibit 1
EXHIBIT 1

CME FX Link Market Maker Program

Program Purpose

The purpose of this Program is to incentivize participants to support the development of CME FX Link and 

to provide liquidity in FX futures traded via CME FX Link. More liquid contracts on the central limit order 

book benefit all participants in the marketplace.

Product Scope

All FX futures traded via CME FX Link on the CME Globex® Platform (“Products”).

Eligible Participants

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

members or non-members.

Program Term 

Start date is March 25, 2018. End date is September 30, 2023 September 30, 2024.

Hours

N/A

Obligations

In order to be eligible to receive the incentives, participants must either meet certain minimum volume 

thresholds or meet predetermined quoting obligations in the Products during a certain percentage of timein-market.

Incentives

Upon satisfying all obligations, as determined by the Exchange, participants will be eligible to receive 

predetermined incentives. 

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 obligations of 

the Program.