SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 22-246

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): June 14, 2022 Filing Description: Implementation of the 

Cleared OTC FX Fee Schedule for Non-Deliverable Forwards (NDFs) and Cash-Settled 

Forwards (CSFs)

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: N/A

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

June 14, 2022

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: Implementation of the Cleared OTC FX Fee Schedule for Non-Deliverable 

Forwards (NDFs) and Cash-Settled Forwards (CSFs)

CME Submission No. 22-246

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME”) hereby notifies the Commodity Futures Trading Commission 

(“CFTC” or “Commission”) that it plans to implement fees (“Fee Schedule”) that apply to over-the-counter 

(“OTC”) foreign exchange (“FX”) non-deliverable forwards (“NDFs”) and cash-settled forwards (“CSFs”)

cleared at CME. The proposed Fee Schedule will be effective on July 1, 2022.

Exhibit 1 sets forth the proposed Fee Schedule that will be applicable to OTC FX NDFs and CSFs cleared 

at CME.

CME reviewed the derivatives clearing organization (“DCO”) core principles (“Core Principles”) as set 

forth in the Commodity Exchange Act (“CEA”). During the review, CME staff identified the following Core 

Principles as potentially being impacted.

• Public Information: As required by this Core Principle, CME will publish the Fee Schedule on 

the CME Group website to ensure that market participants have been advised of the fees. 

• Financial Resources: The proposed fees will not impact CME’s ability to discharge its financial, 

operational, or managerial responsibilities as a DCO.

CME certifies that the Fee Schedule set forth in Exhibit 1 complies with the CEA and the regulations 

thereunder. There were no substantive opposing views to the Fee Schedule. 

CME certifies that this submission has been concurrently posted on CME’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 CME Submission No. 22-246 in any related 

correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

CME CLEARED OTC FX FEE SCHEDULE 

NON-DELIVERABLE FORWARDS (NDFs) AND CASH-SETTLED FORWARDS 

(CSFs)

Clearing Fee:

• Charged on all cleared trades (including new, terminations, compressions, and backloads)

• There are no transaction fees for transfers

• Clearing fees are billed in USD

• Applies to both customer and house accounts

Fee Type Trade Types Products HOUSE CUSTOMER

Clearing Fee All Trade 

Types

OTC FX NDFs – all currencies

$1.00 per million in USDE 

notional

OTC FX CSFs – all currencies

*For non-USD based currency pairs supported by CME, the notional traded in the base currency will 

be multiplied by the exchange rate (rounded to 4 decimal places) to convert to USD. The fee of $1.00 

per million USDE notional would then be charged on that value. 

Blending and Netting:

• There will be no charges associated with the blending and netting of positions.