433 West Van Buren Street › Suite 700S › Chicago, IL 60607 › cboe.com

May 4, 2023

Mr. Christopher Kirkpatrick

Secretary

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Cboe Futures Exchange, LLC Rule Certification

Submission Number CFE-2023-008

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and 

Regulation 40.6(a) of the regulations promulgated by the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) under the Act, Cboe Futures Exchange, LLC (“CFE” or 

“Exchange”) hereby submits an updated CFE Fee Schedule for fees filed with the Commission 

(“Amendment”). Exhibit 1 to this submission sets forth the changes included in the Amendment 

to the CFE Fee Schedule for fees filed with the Commission. The Amendment will become 

effective on June 1, 2023.

The Amendment includes the following CFE Fee Schedule revisions:

• The Amendment establishes customer and block trade transaction fees for Options on 

Cboe® iBoxx® iShares® Bond Index Futures (“CB Options”) to be traded on CFE. 

These transaction fees will begin to apply when CB Options are first listed for trading 

on CFE. These transaction fees are the same fees that currently apply to customer 

and block trade transactions in Cboe® iBoxx® iShares® Bond Index futures (“CB 

Index Futures”) traded on CFE.

• The Amendment revises the disclaimer provisions at the end of the CFE Fee 

Schedule with respect to CB Index Futures that relate to Markit Indices Limited and 

BlackRock Fund Advisors. In particular, the Amendment incorporates references to 

CB Options into those disclaimer provisions in addition to the current references in

those provisions to CB Index Futures. See Exhibit 1 to this submission for those 

updated disclaimers and for related trademark information relating to Markit Indices 

Limited and BlackRock Fund Advisors.

CFE believes that the Amendment is consistent with Designated Contract Market 

(“DCM”) Core Principles 2 (Compliance with Rules) and 7 (Availability of General Information) 

under Section 5 of the Act because the amended fees are equitable and do not unfairly 

discriminate and the Amendment sets forth in a clear and transparent way the manner in which 

CFE applies its fees.
2

CFE believes that the impact of the Amendment will be beneficial to the public and 

market participants. CFE is not aware of any substantive opposing views to the Amendment. 

CFE hereby certifies that the Amendment complies with the Act and the regulations thereunder. 

CFE further certifies that CFE has posted a notice of pending certification with the Commission 

and a copy of this submission on CFE’s website 

(http://www.cboe.com/us/futures/regulation/rule_filings/cfe/) concurrent with the filing of this 

submission with the Commission.

Questions regarding this submission may be directed to Arthur Reinstein at (312) 786-

7570 and Shane Wilkerson at (484) 798-9350. Please reference our submission number CFE2023-008 in any related correspondence.

Cboe Futures Exchange, LLC

 /s/ Laura Fuson

By: Laura Fuson

Managing Director
3

EXHIBIT 1

The Amendment, marked to show additions in double-underlined text and deletions in 

stricken text, consists of the following:

* * * * *

CFE Fee Schedule1, 

F

2

For Fees Filed with the Commodity Futures Trading Commission

Effective April 1, 2023June 1, 2023

1.a. Transaction Fees in Cboe Volatility Index (Standard) 

(VX) Futures and Weekly (Non-Standard) Cboe 

Volatility Index (VX) Futures3:

Per Contract Side

A. CFE TPH Permit Holder4 $1.10

(This rate may be reduced by a rebate based upon a 

TPH’s Average Daily VX TPH Volume as specified

below)5:

Tier

Average Daily VX TPH Volume

for Applicable Month Rebate Per Contract Side

1 ≥ 250 $0.04 Rebate

2 ≥ 500 $0.11 Rebate

3 ≥ 1,000 $0.18 Rebate

4 ≥ 1,500 $0.21 Rebate

5 ≥ 2,000 $0.24 Rebate

6 ≥ 2,500 $0.27 Rebate

7 ≥ 3,000 $0.30 Rebate

8 ≥ 4,000 $0.34 Rebate

9 ≥ 6,000 $0.39 Rebate

10 ≥ 8,000 $0.41 Rebate

11 ≥ 10,000 $0.43 Rebate

12 ≥ 25,000 $0.45 Rebate

13 ≥ 40,000 $0.47 Rebate

14 ≥ 65,000 $0.50 Rebate

15 ≥ 100,000 $0.54 Rebate

Per Contract Side

B. Customer6 $1.47

C. Block Trades

1. CFE TPH Permit Holder4

a. Non-TAS Block Trade $1.00

2. Customer6

a. TAS Block Trade $1.00

b. Non-TAS Block Trade $1.00

(Fees are in addition to other applicable

transaction fees)

1.b. Transaction Fees in S&P 500 Variance (VA) Futures:

• Standard Transactions By contract side per 1,000 Vega Notional

A. CFE TPH Permit Holder4 $4.00
4

B. Customer6 $8.00

C. Block Trade $1.00

(Fee is in addition to other applicable transaction

fees. Block Trades are not permitted in stub

positions in S&P 500 Variance Futures)

1.c. Transaction Fees in Cboe® iBoxx® iShares® Bond (CB) 

Index Futures and Options on Cboe® iBoxx® iShares®

Bond Index Futures*:

Per Contract Side

B. Customer6 $1.00

C. Block Trade $1.00

(Fee is in addition to other applicable transaction 

fees)

*iBoxx® is a service mark IHS Markit Limited. 

iShares® is a registered trademark of BlackRock Fund 

Advisors and its affiliates.

1.d. Transaction Fees in AMERIBOR® Futures*: Per Contract Side

A. CFE TPH Permit Holder4 $1.40

B. Customer6 $1.40

C. Block Trade $1.35

(Fee is in addition to other applicable transaction fees)

*AMERIBOR® is a registered trademark of 

Environmental Financial Products, LLC.

CFE assesses the Transaction Fees set forth above to the Clearing Member associated with the EFID for the 

execution that is identified on the trade record for the applicable transaction, regardless of whether the trade 

is given up to another Clearing Member for clearing and regardless of whether a different Clearing Member 

has been identified as the designated Clearing Member for the payment of Exchange fees by the CFE TPH 

that executed the trade.

2. Trading Permit Fees:7 Amount8

A. Clearing Firm $100/month

B. Proprietary Trading/Pool Manager/

Pooled Investment Vehicle $1,000/month

C. Broker $700/month

3. Applications Fees: Amount

A. Individual9

B. Organization10

C. Investigation Fee10

$500

$1,000

$135/Investigation

4. Billing Process Through Clearing Corporation:

Every Trading Privilege Holder must designate, in a form and manner prescribed by the Exchange,

a Clearing Member for the payment of the Trading Privilege Holder’s Exchange fees designated by 

the Exchange (other than for Transaction Fees), for the payment of vendor fees for Exchangerelated services designated by the Exchange, and for the receipt of Exchange payments designated 

by the Exchange. The designated Clearing Member shall pay to the Exchange on a timely basis any 

fee amount that is not disputed in accordance with footnote 2 of this Fee Schedule by the Trading 

Privilege Holder that is directly involved. Such payments shall be collected by the Exchange 

against the designated Clearing Member’s account at the Clearing Corporation. Exchange 
5

Transaction Fees are also assessed pursuant to this procedure to the Clearing Member associated 

with the EFID for the execution that is identified on the trade record for the applicable transaction. 

The Clearing Corporation shall have no liability in connection with forwarding to the Exchange 

payments drafted pursuant to this procedure or forwarding to Clearing Members payments made to 

Trading Privilege Holders by the Exchange pursuant to this procedure. A Clearing Member 

designated or assessed Exchange Transaction Fees pursuant to this procedure functions as a 

conduit for the collection of the fees covered by this procedure that are owed by the applicable 

Trading Privilege Holder and not as a guarantor for the payment of those fees by another Trading 

Privilege Holder. Similarly, a Clearing Member designated pursuant to this procedure functions as 

a conduit for the receipt and provision to the applicable Trading Privilege Holder of Exchange 

payments to that Trading Privilege Holder made pursuant to this procedure.

1

 CFE fees are invoiced at the beginning of each month for the previous month of service.

2

 Any potential billing errors relating to fees assessed by CFE must be brought to the attention of CFE’s Accounting 

Department within 90 days from the invoice date. All fees assessed shall be deemed final and non-refundable after 90 

days from the invoice date if notice of a potential billing error is not provided, or CFE does not otherwise identify the 

billing error, within that time frame. If transaction fees are billed at an incorrect rate because of an incorrect Customer 

Type Indicator (“CTI”) code that was included in an order or transaction report submission and the Exchange later 

assesses additional fees for or provides a refund with respect to those transactions based on the correct CTI code, the 

additional fee assessment or refund shall be determined in the following manner. The additional fee assessment or 

refund shall only be applicable with respect to the 90 day period referenced above. The additional fee assessment or 

refund for transactions during that 90 day period will be equal to the number of executed contracts that were assessed at 

an incorrect rate multiplied by the difference between the highest potential customer rate and the highest potential TPH 

rate for the relevant product under the CFE Fee Schedule during the that time period. This calculation will not be 

adjusted for any potential or previous rebate payments and no adjustments will be made to any rebate payments to the 

applicable party or to other parties because of the use of an incorrect CTI code. This calculation will also not be 

adjusted for any maker, taker, or market turner designations for executions. The provisions of this footnote are not 

applicable to payment obligations from market data audits under the Cboe Global Markets Global Data Audit Policy.

3

 The fees and rebate schedules in Section 1.a. are applicable to VX futures contracts with a VX or VXT ticker symbol 

(“Standard VX Futures”) and to Weekly (Non-Standard) VX futures contracts with a VX or VXT ticker symbol 

followed by a number denoting the specific week of the calendar year in which the contract expires (“Weekly VX 

Futures”).

4

 CFE TPH Permit Holder transaction fee rates are applied to the execution of orders, Block Trades, and Exchange of 

Contract for Related position transactions for which the applicable CTI code is CTI Code 1, CTI Code 2, or CTI Code 

3.

5

 Transaction fees for Trading Privilege Holder (“TPH”) transactions in VX futures that qualify as VX TPH Volume 

are subject to a rebate schedule. For this purpose, VX TPH Volume includes all TPH transaction volume in VX futures 

for which the applicable CTI code is 1, 2, or 3, including Trade at Settlement (“TAS”) transactions in VX futures with 

one of those CTI codes and Block Trades and Exchange of Contract for Related Position transactions in VX futures 

with one of those CTI codes. VX TPH Volume includes TPH transaction volume both in Standard VX Futures and in 

Weekly VX Futures. A TPH may qualify for the rebate based upon the average daily VX TPH Volume of the TPH 

during the applicable calendar month. The amount of the rebate is based upon the tier level of the average daily VX 

TPH Volume of the TPH for the applicable calendar month. Only the highest tier level within the rebate schedule for 

which a TPH qualifies for the applicable calendar month is applied for that calendar month. If a TPH qualifies for the 

rebate for a calendar month, the amount of the TPH’s VX TPH Volume during the calendar month is multiplied by the 

applicable rebate from the rebate schedule to arrive at a total TPH VX transaction fee rebate amount for the calendar 

month for that TPH. For purposes of qualification for the rebate, a TPH’s VX TPH Volume solely includes trading 

volume resulting from transactions executed by that TPH using an EFID assigned to that TPH.
6

Affiliated TPHs that have at least 75% of their direct or indirect ownership in common are eligible to have their VX 

TPH Volume aggregated for purposes of satisfaction by each of the TPHs of the applicable tier level under the rebate 

schedule with respect to average daily VX TPH Volume. TPHs must request this aggregation in a form and manner 

prescribed by the Exchange. The aggregation shall be applied starting with the calendar month following the month in 

which the Exchange determines that the TPHs qualify for the aggregation. The aggregation shall apply solely with 

respect to VX TPH Volume resulting from transactions executed by the affiliated TPHs using their own EFIDs.

The VX TPH Volume of any Pool Manager(s) and associated Pool(s) that are treated as a collective Trading Privilege 

Holder under CFE rules which results from transactions executed using their own EFIDs is aggregated for purposes of 

satisfaction of the applicable tier level under the rebate schedule with respect to average daily VX TPH Volume.

6

 Customer transaction fee rates are applied to the execution of orders, Block Trades, and Exchange of Contract for 

Related position transactions for which the applicable CTI code is CTI Code 4.

7

 A TPH shall be entitled to obtain a single Trading Permit. A Pool Manager may obtain a single Trading Permit for 

the Pool Manager and all of the Pools approved under Rule 305A for which it acts as Pool Manager. If there is more 

than one Pool Manager for a Pool or Pools, the Pool Managers for the Pool(s) may obtain a single Trading Permit for 

the Pool Managers and all of the Pools approved under Rule 305A for which they act as Pool Manager. The monthly 

fee for a Trading Permit is based on the capacity or capacities of the TPH on CFE. There are three categories of

capacities specified in the CFE Fee Schedule. If a TPH has capacities in multiple categories, the TPH is assessed the 

monthly Trading Permit fee for each category. If a TPH has capacities in the same category, the monthly Trading 

Permit fee for that category covers all capacities in that category and the TPH is not assessed an additional monthly 

Trading Permit fee for that category. The following capacities have the following meanings solely for the purpose of 

assessment of Trading Permit fees:

Clearing Firm: A Trading Privilege Holder has a Clearing Firm capacity if the Trading Privilege Holder (i) is a 

member of the Clearing Corporation that is authorized under the rules of the Clearing Corporation to clear trades in 

Contracts traded on the Exchange and (ii) guarantees and/or clears transactions on the Exchange executed by the 

Trading Privilege Holder itself and/or one or more other Trading Privilege Holder(s). If a Clearing Member 

executes transactions on the Exchange as agent for one or more other Person(s), the Clearing Member shall also be 

deemed to have a Broker capacity. If a Clearing Member executes transactions on the Exchange for its own 

account, the Clearing Member shall also be deemed to have a Proprietary Trading capacity.

Broker: A Trading Privilege Holder has a Broker capacity if the Trading Privilege Holder executes transactions on 

the Exchange as agent for one or more other Person(s). If a Trading Privilege Holder with a Broker capacity 

executes transactions on the Exchange for the Trading Privilege Holder’s own account, the Trading Privilege 

Holder shall also be deemed to have a Proprietary Trading capacity. If a Trading Privilege Holder has a 

Proprietary Trading capacity and the only other Person(s) for which the Trading Privilege Holder executes 

transactions on the Exchange as agent are affiliates of the Trading Privilege Holder, the Trading Privilege Holder 

shall not be deemed to have a Broker capacity for this purpose.

Proprietary Trading: A Trading Privilege Holder has a Proprietary Trading capacity if the Trading Privilege 

Holder executes transactions on the Exchange for the Trading Privilege Holder’s own account.

Pool Manager/Pooled Investment Vehicle (“Pool”): These capacities have the meanings set forth in Rule 305A.

The applicable Trading Permit fee(s) shall be assessed for a calendar month unless a TPH provides notice of the 

termination of a TPH capacity for the purpose of assessment of Trading Permit fees, or of the termination of a Trading 

Permit, in a form and manner prescribed by the Exchange by no later than 4:00 p.m. Chicago time on the second-to-last 

business day of the prior calendar month.

8

 A monthly or quarterly fee under the CFE Fee Schedule will be prorated for the initial month or quarter in which it is 

applicable, with the exception of Device/Authorized User fees which are not prorated for any month in which they are 

applicable. A monthly or quarterly fee under the CFE Fee Schedule is not prorated for the final month or quarter in 
7

which it is applicable (unless that final month or quarter is the same as the initial month or quarter in which the fee is 

applicable).

9

 A single application fee is assessed when one or more Pool Managers and associated Pools initially apply for Trading 

Privileges as a collective Trading Privilege Holder. An application fee is also assessed when the collective Trading 

Privilege Holder adds or replaces a Pool Manager. No application fee is assessed if the collective Trading Privilege 

Holder deletes a Pool Manager or adds or deletes a Pool.

A Trading Permit Holder application fee is not applicable if a former Trading Privilege Holder applies for reinstatement 

as a Trading Privilege Holder within 30 days of termination as a Trading Privilege Holder. 

10 This fee is assessed for each investigation that is conducted of any Trading Privilege Holder applicant; any executive 

officer, authorized signatory, or administrator of an applicant; and any executive officer, authorized signatory, or 

administrator added by an existing Trading Privilege Holder.

The iBoxx® iShares® $ High Yield Corporate Bond Index and the iBoxx® iShares® $ Investment Grade Corporate Bond 

Index (the “Indexes”) referenced herein are the property of Markit Indices Limited (“Index Sponsor”) and have been 

licensed for use in connection with Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, Options on 

Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, and Cboe® iBoxx® iShares® $ Investment Grade 

Corporate Bond Index Futures and Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index 

Futures. Each party to a transaction in Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, Options on 

Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, or Cboe® iBoxx® iShares® $ Investment Grade 

Corporate Bond Index Futures or Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index 

Futures transaction acknowledges and agrees that the transaction is not sponsored, endorsed or promoted by the Index 

Sponsor. The Index Sponsor makes no representation whatsoever, whether express or implied, and hereby expressly 

disclaims all warranties (including, without limitation, those of merchantability or fitness for a particular purpose or use), 

with respect to the Indexes or any data included therein or relating thereto, and in particular disclaims any warranty either

as to the quality, accuracy and/or completeness of the Indexes or any data included therein, the results obtained from the 

use of the Indexes and/or the composition of the Indexes at any particular time on any particular date or otherwise and/or 

the creditworthiness of any entity, or the likelihood of the occurrence of a credit event or similar event (however defined) 

with respect to an obligation, in the Indexes at any particular time on any particular date or otherwise. The Index Sponsor 

shall not be liable (whether in negligence or otherwise) to the parties or any other person for any error in the Indexes, and 

the Index Sponsor is under no obligation to advise the parties or any person of any error therein.

The Index Sponsor makes no representation whatsoever, whether express or implied, as to the advisability of purchasing or 

selling Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, Options on Cboe® iBoxx® iShares® $ High 

Yield Corporate Bond Index Futures, or Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index Futures,

and Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index Futures; the ability of the Indexes to 

track relevant markets’ performances,; or otherwise relating to the Indexes or any transaction or product with respect 

thereto, or of assuming any risks in connection therewith. The Index Sponsor has no obligation to take the needs of any 

party into consideration in determining, composing or calculating the Indexes. No party purchasing or selling 

Cboe® iBoxx® iShares® $ High Yield Corporate Bond Index Futures, Options on Cboe® iBoxx® iShares® $ High Yield 

Corporate Bond Index Futures, or Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index Futures or 

Options on Cboe® iBoxx® iShares® $ Investment Grade Corporate Bond Index Futures, nor the Index Sponsor, shall 

have any liability to any party for any act or failure to act by the Index Sponsor in connection with the determination, 

adjustment, calculation or maintenance of the Indexes.

iBoxx® is a service mark of IHS Markit Limited.

The iBoxx® iShares® $ High Yield Corporate Bond Index and the iBoxx® iShares® $ Investment Grade Corporate Bond 

Index (the “Indexes”), and futures contracts on the Indexes and options on futures contracts on the Indexes (“Contracts”) 

are not sponsored by, or sold by BlackRock, Inc. or any of its affiliates (collectively, “BlackRock”). BlackRock makes no 

representation or warranty, express or implied to any person regarding the advisability of investing in securities, generally, 

or in the Contracts in particular. Nor does BlackRock make any representation or warranty as to the ability of the Indexes 
8

to track the performance of the fixed income securities market, generally, or the performance of HYG, LQD or any subset 

of fixed income securities.

BlackRock has not calculated, composed or determined the constituents or weightings of the fixed income securities that 

comprise the Indexes (“Underlying Data”). BlackRock is not responsible for and has not participated in the determination 

of the prices and amounts of the Contracts, or the timing of the issuance or sale of such Contracts or in the determination or 

calculation of the equation by which the Contracts are to be converted into cash (if applicable). BlackRock has no 

obligation or liability in connection with the administration or trading of the Contracts. BlackRock does not guarantee the 

accuracy or the completeness of the Underlying Data and any data included therein and BlackRock shall have no liability 

for any errors, omissions or interruptions related thereto.

BlackRock makes no warranty, express or implied, as to results to be obtained by Markit or its affiliates, the parties to the

Contracts or any other person with respect to the use of the Underlying Data or any data included therein. BlackRock 

makes no express or implied warranties and expressly disclaims all warranties of merchantability or fitness for a particular 

purpose or use with respect to the Underlying Data or any data included therein. Without limiting any of the foregoing, in 

no event shall BlackRock have any liability for any special, punitive, direct, indirect or consequential damages (including 

lost profits) resulting from the use of the Underlying Data or any data included therein, even if notified of the possibility of 

such damages. 

iShares® is a registered trade mark of BlackRock Fund Advisors and its affiliates.