SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-291 (2 of 4)

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): July 17, 2023 Filing Description: Modifications to the 

International Cross-Asset Volume 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: 
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

July 17, 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 International Cross-Asset Volume Incentive Program

CBOT Submission No. 23-291 (2 of 4)

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME”), The Board of Trade of the City of Chicago, Inc. (“CBOT”), New York 

Mercantile Exchange, Inc. (“NYMEX”), and Commodity Exchange, Inc. (“COMEX”) (collectively, the “Exchanges”) 

hereby notify the Commodity Futures Trading Commission (“CFTC” or “Commission”) of modifications to the 

International Cross-Asset Volume Incentive Program (“IVIP” or “Program”). The modifications to the Program will 

become effective on August 1, 2023. 

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

overstruck. 

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

Commodity Exchange Act (“CEA”). During the review, the Exchanges’ 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 Exchanges’ ability to perform their trade practice and market surveillance 

obligations under the CEA. The Exchanges’ market regulation staff will monitor trading in the Program’s products to 

prevent manipulative trading and market abuse. The incentives in the Program do not impact the Exchanges’ order 

execution. Participants in the Program will be selected by the Exchanges’ staff using criteria as further stated in 

Exhibit 1. Chapter 4 of the Exchanges’ rules includes prohibitions against fraudulent, non-competitive, unfair or 

abusive practices. The Program is subject to these rules. The Program is subject to the Exchanges’ record retention 

policies which comply with the CEA.

CME, CBOT, NYMEX, and COMEX certify that the Program complies with the CEA and the regulations thereunder. 

There were no substantive opposing views to this Program.

The Exchanges certify that this submission has been concurrently posted on the Exchanges’ 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 CBOT Submission No. 23-291 in any related 

correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

INTERNATIONAL CROSS-ASSET VOLUME INCENTIVE PROGRAM 

Program Purpose 

The purpose of this Program is to incentivize high volume proprietary trading arcades located outside 

North America to trade the products listed below. The resulting increase in liquidity in the products listed 

below benefits all participant segments in the market. 

Product Scope

Certain CME, CBOT, NYMEX, and COMEX products that are available for trading on the CME Globex 

Platform; all CME Interest Rate options available for trading via open outcry (collectively, the “Products”). 

Eligible Participants

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

distinct legal entities located outside of North America.

Additional Arcade Firm Requirements:

• Teams of individuals with joint profits and losses under a participating arcade firm must be 

registered and approved by the Exchanges to be eligible for discounted rates under the arcade 

firm. Teams that adjust their legal status for the purpose of achieving lower combined rates may 

not be accepted into the Program. If firms have affiliates based in North America, they must 

apply for an exception.

• Individual traders under the participating arcade firm must be receiving less than eighty percent 

(80%) of profits and losses* and:

o Have primary income coming from trading; 

o Pay a desk fee;

o Primarily trade from the physical location operated by the participating arcade firm;

o Share risk with the participating arcade firm; and

o Be available to receive product notices and education.

*Participants previously enrolled in the Program may receive up to ninety percent (90%) of profits 

and losses.

Program Term 

Start date is November 1, 2012. End date is July 31, 2023 January 31, 2024.

Hours

The incentives will apply to all trades made in the Products regardless of the execution time.

Obligations

For continued eligibility and incentive qualification, participants must maintain a combined average daily 

volume (“ADV”) in the Products of 2,500 5,000 contracts (sides) measured over a given calendar quarter. 

Micro E-mini Equity Index products will be excluded from this ADV requirement.
Incentives

Fee Discounts: Upon meeting all obligations, as determined by the Exchanges, participants will receive 

the following incentives:

Product Category

CME Globex Only

IVIP All-in Fees

(Per Side)

CME Products

Agricultural – Futures1 $0.89

Agricultural – Options

1 $0.89

Lumber Futures $0.82

Weather Contracts $0.26

Full Size Foreign Exchange – Futures

(excluding FX Link) $0.54

Full Size Foreign Exchange – Futures via FX 

Link

$0.60

Foreign Exchange – Options $0.54

E-mini Foreign Exchange Contracts $0.54

E-micro Foreign Exchange Contracts $0.15

Full Size Equity Index – Futures $1.10

E-mini Equity Index – Futures (Outrights & 

Spreads) $0.70

E-mini Equity Index – Options $0.50

Micro E-Mini Equity Index Futures $0.18

Micro E-mini Equity Index – Options (Outrights 

& Spreads)

$0.10

Nikkei/TOPIX Futures (Outrights & Spreads) $1.10

Interest Rate Futures $0.50

Interest Rate Options $0.50

CBOT Products

Full Size Agricultural Contracts1 $1.11

Mini Agricultural Contracts $0.90

ICS & CS Agricultural Options $2.06

E-mini Dow/DJ U.S. Real Estate $0.70

Micro E-Mini Dow Futures $0.18

Eris Swap Futures $0.50

Micro Treasury Yield Futures $0.21

TBA Futures $0.50

U.S. Treasury Futures $0.54

U.S. Treasury Options $0.54

Fed Fund Products $0.49

MAC Swap Futures $0.49
Product Category

NYMEX Products on CME Globex

IVIP All-in Fees

(Per Side)

Core Energy (CL, LO, HO, OH, RB, OB, NG, 

LN, ON)1 $0.90

NYMEX Metals (PL, PA)1 $1.00

All other Energy Must be 10% greater than 

the highest member rate

COMEX Products on CME Globex –

Futures Only 

Core Metal (GC, SI, HG)

1 $1.00

E-micro Gold (MGC) $0.20

1,000 oz. Silver (SIL) $0.40

Shanghai Gold (SGC, SGU) $1.00

Gold (Enhanced Delivery) Futures (4GC) $1.00

Product Category

Pit Trading

IVIP All-in Fees

(Per side)

CME Products

Interest Rate Options $0.50

1For the products denoted with a 1 above, Globex TAS transactions will be excluded from the Program

upon implementation by the Exchanges.

Monitoring and Termination of Status

The Exchanges 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 or fails to meet the obligations of the Program.

If a participant does not meet the minimum volume requirements during one (1) calendar quarter of the 

Program, the participant will still be eligible to receive the incentives for that applicable quarter. In order to 

continue to receive the incentives, participants must meet the minimum volume requirements for all 

subsequent calendar quarters.