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Via Portal Submission 

May 15, 2023

MGEX Submission No. 23-25

Mr. Christopher J. 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 CFTC Regulation 40.6(a); Modifications to the SPIKES 

Market Maker Program

Dear Mr. Kirkpatrick:

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

Commission (“CFTC”) Regulation 40.6(a), the Minneapolis Grain Exchange, LLC (“MGEX”) hereby notifies 

the CFTC of its intention to modify the SPIKES Market Maker Program (“Program”). The modifications to 

the Program will become effective on June 1, 2023.

Exhibit 1 sets forth the terms of the Program. Modifications appear below, with additions underlined and 

deletions in strikethough.

MGEX has reviewed the Core Principles for designated contract markets (“DCM Core Principles”) and 

identified that the Program may impact the following DCM Core Principles:

• DCM Core Principle 2, Compliance with Rules: The Program is established pursuant to existing 

MGEX Rule 2.1.11. Participants in the Program will be selected by the Exchange using criteria as 

stated in Exhibit 1. MGEX will monitor Program participants’ activity to ensure proper distribution 

of earned incentives.

• DCM Core Principle 4, Prevention of Market Disruption: The Program will not impact MGEX’s 

ability to perform its trade practice and market surveillance obligations under the CEA, CFTC 

Regulations, and its Rules. MGEX will monitor trading in the Program to prevent manipulative 

trading and market abuse.

• DCM Core Principle 7, Availability of General Information: The terms of the Program have been 

disseminated on the MGEX website. For further inquiry, Market Participants may contact MGEX 

for more information regarding the Program.

• DCM Core Principle 9, Execution of Transactions: The product included in this Program is listed 

for trading in the open and competitive market.

• DCM Core Principle 12, Protection of Markets and Market Participants: The Program is subject to 

MGEX Rules, which includes prohibitions against abusive practices, including fraudulent, 

noncompetitive, or unfair actions.

• DCM Core Principle 18, Recordkeeping: Certain participants in the Program must execute a 

contractual agreement with MGEX in which each participant will expressly agree to comply with 
MINNEAPOLIS GRAIN EXCHANGE, LLC

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

612-321-7101

mgex.com

and be subject to applicable regulations and MGEX Rules. The Program is subject to MGEX’s 

record retention policies, which comply with the CEA and CFTC Regulations.

Pursuant to the authority set forth in MGEX Rule 2.1.11., the Exchange has approved the Program. There 

were no substantive opposing views to this Program, nor is MGEX aware of any substantive opposing views 

with respect to this filing. 

The Program is intended to become effective ten (10) business days from the date of this submission. If 

there are any questions regarding this submission, please contact me at (612) 321-7128. Thank you for 

your attention to this matter.

Sincerely,

Peter D. Sparby

Vice President, Counsel

Enclosure