SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 23-329

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 08/15/23 Filing Description: Amendments to the Block Trade 

Minimum Quantity Threshold for Foreign Exchange (“FX”) Inter-Commodity Option 

Combinations 

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

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

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Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

August 15, 2023

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 40.6(a) Certification. Amendments to the Block Trade 

Minimum Quantity Threshold for Foreign Exchange (“FX”) Inter-Commodity 

Option Combinations.

CME Submission No. 23-329

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME” or “Exchange”) certifies to the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) amendments to the block trade minimum quantity threshold for all 

foreign exchange (“FX”) inter-commodity option combinations (collectively, the “Contracts”) such that the 

sum of the quantities of the legs of the transaction must meet the larger of the threshold requirements for 

block trades as detailed in Exhibit A below (collectively, the “Rule Amendments”) effective on Sunday, 

September 10, 2023 for trade date Monday, September 11, 2023. 

Exhibit A

Block Minimum Thresholds Table

Additions are highlighted in red underline; deletions are highlighted in red strikethrough.

Block Trade Minimum Thresholds and Reporting Times for Spreads and 

Combination Transactions

CME and CBOT Products NYMEX and COMEX Products

Each leg of the spread must meet 

the designated minimum quantity 

threshold.

Intra-Commodity Options

Spreads and Options

Combinations

** Exceptions apply in:

i)Foreign Exchange Options; and;

The sum of the quantities of the legs of 

the transaction must meet the minimum 

block quantity threshold

ii)Dairy Options.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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Inter-Commodity Options

Spreads and Options

Combinations

Each leg of the spread must meet 

the larger of the threshold 

requirements for the underlying 

products.

  Exceptions apply in:

i)Short Term Interest Rate Options;

ii) Dairy Options; and

iii) Select Grain Options.; and

iv) Foreign Exchange Options.

The sum of the quantities of the legs of 

the transaction must meet the larger of 

the threshold requirements for the 

underlying products

**  Exception for Intra-Commodity Options Spreads and Options Combinations

i) Intra-Commodity Foreign Exchange Options

For intra-commodity Foreign Exchange options spreads and options combinations, the sum of

the quantities of the legs of the transaction must meet the minimum block quantity threshold.

**** Exception for Inter-Commodity Options Spreads and Options Combinations

iv) Inter-Commodity Foreign Exchange Options

For inter-commodity Foreign Exchange options spreads and options combinations, the sum of the

quantities of the legs of the transaction must meet the larger of the threshold requirements for the

underlying products

The Rule Amendments are intended to harmonize the block trade minimum quantity threshold levels of FX 

Intra- and Inter-Commodity option combinations.

The Exchanges 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: The Exchange shall disseminate a Special Executive Report 

(“SER”) that sets forth information with regard to specifications, terms, and conditions of the 

Contracts. In addition to such SER, daily trading volume, open interest, and price information for 

the Contracts shall be published on the Exchange’s website. 

• Daily Publication of Trading Information: The Exchange shall publish trading volumes, open 

interest levels, and price information daily of the transactions on the CME Group website.

• Compliance with Rules: The Exchange will continue its normal practice to establish, monitor, and 

enforce compliance with the rules of the transactions.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.6(a), the Exchange certify that the Rule 

Amendments comply with the Act, including regulations under the Act. There were no substantive opposing 

views to this proposal.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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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.

Should you have any questions concerning the above, please contact the undersigned at (212) 299-2200 

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

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel