SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 24-083

Organization: The Board of Trade of the City of Chicago, Inc. ("CBOT")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 01/22/24 Filing Description: Amendments to Rule 15108. 

(“Premium Charges”) to Increase the Maximum Premium Charges of the Oat Futures 

Contract Commencing with the Conclusion of the July 2024 Delivery Period and Beyond

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: 

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: See filing.

Rule Numbers: See filing.
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

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Timothy Elliott 

Managing Director and Chief Regulatory Counsel

Legal Department

January 22, 2024

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CFTC Regulation 40.4(b)(5). Amendments to Rule 15108. (“Premium

Charges”) to Increase the Maximum Premium Charges of the Oat Futures 

Contract Commencing with the Conclusion of the July 2024 Delivery Period 

and Beyond. 

CBOT Submission No. 24-083

Dear Mr. Kirkpatrick:

The Board of Trade of the City of Chicago, Inc. (“CBOT” or the “Exchange”) is certifying to the Commodity 

Futures Trading Commission (“CFTC” or “Commission”) amendments to Rule 15108. (“Premium Charges”) 

to increase the maximum premium charges of the Oat Futures contract (CME Globex Code: ZO; Rulebook 

Chapter: 15) (the “Contract”) commencing with the conclusion of the July 2024 delivery period (July 19, 

2024) and beyond (collectively, the “Rule Amendments”). This submission shall become effective on 

February 6, 2024.

Specifically, the maximum premium charges for the Contract will increase from 20.5/100s of one cent per 

bushel per day to 26.5/100s of one cent per bushel per day. This is a change from approximately 6 cents 

per bushel per month to approximately 8 cents per bushel per month. This maximum premium charge 

increase will take effect following expiration of the July 2024 contract month. 

Oats: Present – July 18, 2024 Commencing July 19, 2024

 20.5/100 of one cent per bushel per day 26.5/100 of one cent per bushel per day

The Exchange considered both spreads relative to full carry and levels of open interest when determining 

an implementation date for the change to the maximum premium charges. The Exchange determined that 

the spread market of the Contract commencing in July 2024 is well within full carry. In addition, the 

Exchange notes that currently there is minimal open interest in the portion of the curve beyond the July 

2024 contract month.

The Rule Amendments seek to further align the Contract with the related cash market. The storage

economics of CBOT’s Corn and Soybean Futures contracts are similar to that of Oat Futures. The Rule 

Amendments shall align the maximum premium charges across these similar and related contracts. The 

Exchange has conducted comprehensive market participant outreach. Market participants are in favor of 

the Rule Amendments. 
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

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Non-Material Rule Change

The Exchange believes that the Rule Amendments are not material and will not affect a market participant’s

decision to either enter into an existing position or make or take delivery of the Contract. Moreover, the

Exchange believes that the Rule Amendments will not have a material impact on the economic value of 

existing positions in the new crop year.

The Exchange considers a variety of factors when making implementation decisions pertaining to the terms 

and conditions of enumerated agricultural contracts:

• Levels of Open Interest – Per CFTC Regulation 40.4, an exchange can self-certify changes to an 

enumerated agricultural contract if those changes are implemented on contracts without open 

interest. However, since the listing cycle, as of January 12, 2024, extends through July 2026, the 

Exchange needs to balance its obligation to resolve conditions interfering with cash-futures 

convergence against any potential impact on the value of existing positions. Under these 

circumstances, the Exchange evaluates the structure of existing open interest to identify a time 

period where a contract change would make minimal impact. At the close of trade date January 12, 

2024, 4 percent of open interest for oats would be impacted by the change.

• Historical Precedent – Changes to storage and premium rates have typically been implemented 

after expiration of new crop months to coincide with the beginning of the storage rate assessment 

period (the 19th of the delivery month) with the rationale being that the supply and demand dynamics 

for the new crop would be the principal determining factors for the price, as opposed to any 

adjustment to storage rates. Given this historical precedent of implementing storage and premium 

rate changes after new crop contract months expire, any other choice of implementation date could 

be considered somewhat arbitrary. In addition, the Exchange notes that information about planting 

estimates and demand for the subject commodities is not yet available. As a result, in addition to the 

storage rate changes, there are a number of variables that may impact the prices – and spreads –

for oats but cannot be accurately assessed at this time. 

• Spreads Relative to Financial Full Carry – The Exchange looks at calendar spreads relative to full 

storage and financial full carry. Spreads inside full storage and inside financial full carry are not 

being constrained by storage rates, and an increase in storage should theoretically not materially 

affect prices. All calendar spreads out of the July 2024 Oats Futures contract are inside both storage 

and financial full carry as of January 12, 2024.

Exhibit A provides the amendments to Rule 15108, in blackline format, effective on February 6, 2024. 

Exhibit B provides the amendments to Rule 15108, in blackline format, effective on July 19, 2024.

The Exchange reviewed the designated contract market core principles (“Core Principles”) as set forth in 

the Commodity Exchange Act (“CEA” or “Act”) and identified that the Rule Amendments may have some 

bearing on the following Core Principles:

• Availability of General Information: To comply with this Core Principle and to ensure that market 

participants are apprised of the Rule Amendments, the Exchange will make publicly available the 

details of the Rule Amendments herein by publishing a Special Executive Report (“SER”) to the 

market. The SER will also be available on CME Group’s website. 

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.4(b)(5), the Exchange hereby certifies that 

the Rule Amendments comply with the Act, including regulations under the Act. As previously noted, market 

participants are in favor of the proposal. There were no substantive opposing views to the Rule 

Amendments.
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

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The Exchange certifies that this submission has been concurrently posted on the CME Group website at 

http://www.cmegroup.com/market-regulation/rule-filings.html.

Should you have any questions concerning the above, please contact the undersigned at (312) 466-7478 

or via e-mail at CMEGSubmissionInquiry@cmegroup.com.

Sincerely, 

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel

Attachments: Exhibit A: Amendments to CBOT Rule 15108. [Effective February 6, 2024] (blackline 

format)

Exhibit B: Amendments to CBOT Rule 15108. [Effective July 19, 2024] (blackline format)
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Exhibit A

CBOT Rulebook

Chapter 15

Oat Futures

(additions underscored)

[Effective February 6, 2024]

***

15108. PREMIUM CHARGES

(FOR ALL CONTRACT MONTHS UP TO AND THROUGH THE CONCLUSION OF THE JULY 2024 

DELIVERY PERIOD (JULY 18, 2024))

To be valid for delivery on futures contracts, all shipping certificates covering oats under obligation 

for shipment must indicate the applicable premium charge. No shipping certificate shall be valid for 

delivery on futures contracts unless the premium charges on such oats shall have been paid up to and 

including the 18th calendar day of the preceding month, and such payment is endorsed on the shipping 

certificate. Unpaid accumulated premium charges at the posted rate applicable to the facility shall be 

allowed and credited to the buyer by the seller up to and including the date of delivery.

The premium charges on Oats shall not exceed 20.5/100 of one cent per bushel per day.

15108. PREMIUM CHARGES

(FOR ALLCONTRACT MONTHS COMMENCING FOLLOWING THE CONCLUSION OF THE JULY 

2024 DELIVERY PERIOD (JULY 19, 2024))

To be valid for delivery on futures contracts, all shipping certificates covering oats under 

obligation for shipment must indicate the applicable premium charge. No shipping certificate shall be 

valid for delivery on futures contracts unless the premium charges on such oats shall have been paid 

up to and including the 18th calendar day of the preceding month, and such payment is endorsed on 

the shipping certificate. Unpaid accumulated premium charges at the posted rate applicable to the 

facility shall be allowed and credited to the buyer by the seller up to and including the date of delivery.

The premium charges on Oats shall not exceed 26.5/100 of one cent per bushel per day.

[End of Rule.]
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Exhibit B

CBOT Rulebook

Chapter 15

Oat Futures

(deletions struck through)

[Effective on July 19, 2024]

***

15108. PREMIUM CHARGES

(FOR ALL CONTRACT MONTHS UP TO AND THROUGH THE CONCLUSION OF THE JULY 2024 

DELIVERY PERIOD (JULY 18, 2024))

To be valid for delivery on futures contracts, all shipping certificates covering oats under obligation 

for shipment must indicate the applicable premium charge. No shipping certificate shall be valid for 

delivery on futures contracts unless the premium charges on such oats shall have been paid up to and 

including the 18th calendar day of the preceding month, and such payment is endorsed on the shipping 

certificate. Unpaid accumulated premium charges at the posted rate applicable to the facility shall be 

allowed and credited to the buyer by the seller up to and including the date of delivery.

The premium charges on Oats shall not exceed 20.5/100 of one cent per bushel per day.

15108. PREMIUM CHARGES

(FOR ALLCONTRACT MONTHS COMMENCING FOLLOWING THE CONCLUSION OF THE JULY 

2024 DELIVERY PERIOD (JULY 19, 2024))

To be valid for delivery on futures contracts, all shipping certificates covering oats under 

obligation for shipment must indicate the applicable premium charge. No shipping certificate shall be 

valid for delivery on futures contracts unless the premium charges on such oats shall have been paid 

up to and including the 18th calendar day of the preceding month, and such payment is endorsed on 

the shipping certificate. Unpaid accumulated premium charges at the posted rate applicable to the 

facility shall be allowed and credited to the buyer by the seller up to and including the date of delivery.

The premium charges on Oats shall not exceed 26.5/100 of one cent per bushel per day.

[End of Rule.]