SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 24-037

Organization: Commodity Exchange, Inc. ("COMEX")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): January 16, 2024 Filing Description: Modifications to the 

Shanghai Gold Futures Liquidity Provider 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: 
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

Timothy Elliott

Managing Director and Chief Regulatory Counsel

Legal Department

January 16, 2024

VIA ELECTRONIC PORTAL

Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

RE: Modifications to the Shanghai Gold Futures Liquidity Provider Program

COMEX Submission No. 24-037

Dear Mr. Kirkpatrick:

Commodity Exchange, Inc. (“COMEX” or “Exchange”) hereby notifies the Commodity Futures Trading Commission 

(“CFTC” or “Commission”) of plans to modify the Shanghai Gold Futures Liquidity Provider Program (“Program”). The 

modifications to the Program will become effective on February 1, 2024.

Exhibit 1 sets forth the terms of the Program. 

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

Commodity Exchange Act (“CEA” or “Act”). During the review, Exchange 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 Exchange’s ability to perform its trade practice and market surveillance obligations 

under the CEA. The Exchange will monitor trading in the Program’s products to prevent manipulative trading and 

market abuse. Additionally, the Exchange has implemented systems to track Program participants’ volume to ensure 

proper distribution of earned incentives. The products included in this Program are listed for trading in the open and 

competitive market. Participants in the Program will be selected by Exchange staff using criteria as further stated in 

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

abusive practices. All participants must execute a contractual agreement with the Exchange in which each participant 

will expressly agree to comply with and be subject to applicable regulations and Exchange rules. The Program is

subject to the Exchange’s record retention policies which comply with the CEA.

COMEX certifies that the Program complies with the CEA and the regulations thereunder. There were no substantive 

opposing views to this Program.

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.

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 COMEX Submission No. 24-037 in any related 

correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

Shanghai Gold Futures Liquidity Provider Program

Program Purpose

The purpose of this Program is to incentivize participants to support the development of the products

listed below. The resulting additional central limit order book liquidity benefits all participants in the 

market.

Product Scope

Shanghai Gold (USD) Futures (“SGU”) and Shanghai Gold (CNH) Futures (“SGC”) that are traded on the 

CME Globex Platform or cleared through CME ClearPort (“Products”).

Eligible Participants

The Exchange may designate up to ten (10) participants in the Program. Participants may be COMEX 

members or non-members. Potential participants are required to submit an application/bid sheet to the 

Exchange as part of a competitive application process which is used to determine eligibility. In 

determining whether or not a prospective participant is selected to participate in the Program, Exchange 

staff may take into account a variety of factors including the strength of the quoting obligations the 

prospective participant is willing to commit to provide, whether Exchange staff believes that the 

prospective participant can maintain such obligations, and historical volume trading COMEX products and 

similar contracts. The Exchange may, from time to time, add or subtract from the aforementioned 

requirements as it deems necessary.

Program Term 

Start date is October 14, 2019. End date is March 31, 2024.

Hours

RTH, ETH, and ATH.

Obligations

In order to be eligible to receive the incentives, participants must quote two-sided markets in the Products

at predetermined average bid/ask spreads and minimum quote sizes during a certain percentage of timein-market.

Incentives

Upon meeting all obligations, as determined by the Exchange, participants will be eligible to receive 

predetermined incentives.
Monitoring and Termination of Status

The Exchange 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.