SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 22-408

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

Filing as a: DCM SEF DCO SDR

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 09/22/22 Filing Description: Modifications to CME Clearing’s

Risk Management Framework and Manual of Operations

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: See filing.

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:
20 S. Wacker Drive Chicago, IL 60606 T 312 930 8167 Sean.Downey@cmegroup.com cmegroup.com

1

Sean Downey

Clearing Chief Compliance Officer & Head of Policy

CME Clearing

September 22, 2022

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: CFTC Regulation 40.6(a) Certification. Modifications to CME

Clearing’s Risk Management Framework and Manual of 

Operations.

CME Submission No. 22-408

Dear Mr. Kirkpatrick:

Pursuant toCommodityFutures Trading Commission (“CFTC” or“Commission”) Regulation 40.6(a), Chicago

Mercantile Exchange Inc. (“CME” or “Clearing House”), as a derivatives clearing organization (“DCO”),

certifies to the Commission modifications to CME’s Risk Management Framework (“RMF”) and Clearing 

House Manual of Operations (“MOP”) (collectively, the “Policies”) effective on 

October 7, 2022 (collectively, the “Amendments”).

The RMF, maintained in accordance with CFTC Regulation 39.13(b), is approved by CME’s Board of 

Directors (“Board”) and the Clearing House Oversight Committee (“CHOC”) (i.e., committee established 

by the Board), as applicable, pursuant to the governance arrangements established under the RMF. The

Amendments to the RMF were approved by CHOC. The MOP is maintained in accordance with CME Rule 

801 and non-substantive changes may be approved by the Chief Compliance Officer (“CCO”) of the 

Clearing House. The Amendments to the MOP were approved by the CCO of the Clearing House.1

Specifically, the Amendments to the RMF codify and enhance the Clearing House’s long-standing practice

of seeking risk-based feedback from market participants when launching new products. In particular, these

Amendments provide that public advisory notices in connection with the launch of new products shall

include an express request that risk-specific feedback be provided to the Clearing House. Moreover, to 

the extent any substantive negative risk-based feedback is received pursuant to the issuance of such 

advisory notices or otherwise, the Clearing House will review and document such feedback. 

In addition, the Amendments to the Policies include the replacement of the term “President of the Clearing 

House” with “Global Head of Clearing & Post-Trade Services” and are consistent with CME Submission

No. 22-185.

2

 

DCO Core Principle Review

CME reviewed the DCO core principles (“Core Principles”) as set forth in the Commodity Exchange Act

(“CEA” or “Act”) and identified that the Amendments may have some bearing on the following principles:

1 Note, the title of current CCO of the Clearing House is the Clearing Chief Compliance Officer & Head of Policy.

2 See https://www.cmegroup.com/content/dam/cmegroup/market-regulation/rule-filings/2022/7/22-185_1.pdf
20 S. Wacker Drive Chicago, IL 60606 T 312 930 8167 Sean.Downey@cmegroup.com cmegroup.com

2

• DCO Core Principle A – Compliance: The Amendments to replace the term “President of 

the Clearing House” are in line with the Clearing House’s obligation to ensure that its rules 

are accurate.

• DCO Core Principle O – Governance Fitness Standards: The Amendments enhance the 

Clearing House’s governance arrangements to further promote public interest considerations.

CME has requested confidential treatment with respect to revisions to the Policies, which has been submitted 

concurrently with this submission. CME certifies that the Amendments comply with the Act and regulations

thereunder. There were no substantive opposing views to this action.

If you require any additional information regarding this submission, please contact me at 312-930-8167 or

via email at sean.downey@cmegroup.com. 

Sincerely,

/s/Sean Downey

Clearing Chief Compliance Officer& Head of Policy

CME Clearing

Attachments: Exhibit A – Modified Risk Management Framework (attached under separate cover) (confidential 

treatment requested)

Exhibit B – Modified Clearing House Manual of Operations (attached under separate cover) 

(confidential treatment requested)