Via Portal Submission

August 25, 2023

MGEX Submission No. 23-45

Mr. Christopher Kirkpatrick

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

RE: Rule Certification Submission Pursuant to Regulation 40.6(a); Amendments to MGEX Rules

Dear Mr. Kirkpatrick:

Pursuant to Commodity Exchange Act (“CEAct”) Section 5c and Commodity Futures Trading Commission 

(“CFTC” or “Commission”) Regulation 40.6(a), the Minneapolis Grain Exchange, LLC (“MGEX” or 

“Exchange”) hereby certifies that the addition of MGEX Rule 3.6.13. (the “Proposed Amendments”), as set 

forth in Exhibit A, complies with the CEAct and the Commission regulations promulgated thereunder. MGEX 

further certifies that the submission and pending changes to the MGEX Rules have been posted on the 

Exchange website at the following link: http://www.mgex.com/regulation.html.

Overview of Rule Amendments

The Proposed Amendments expressly prohibit the abusive trading practice commonly known in the 

derivatives industry as “front running”.

DCM Core Principles

MGEX has reviewed the Core Principles for designated contract markets (“DCM Core Principles”) and 

identified that the Proposed Amendments may impact the following DCM Core Principles:

• DCM Core Principle 2 – Compliance with Rules: The Proposed Amendments expressly prohibit 

front running activity, in accordance with the abusive trading practices prohibited by CFTC 

Regulation 38.152.

• DCM Core Principle 4 – Prevention of Market Disruption: The Proposed Amendments codify the 

Exchange's authority enforce the prohibition of front running in compliance with this Core Principle.

• DCM Core Principle 7 – Availability of General Information: The Proposed Amendments have been 

disseminated on the MGEX website, and will be available in the MGEX Rulebook, which is 

accessible online.

• DCM Core Principle 12 – Protection of Markets and Market Participants: The Proposed 

Amendments will protect the market and market particiants by expressly prohibiting the abusive 

trading practice of front running.
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7101

mgex.com

Pursuant to MGEX Bylaw 3.1., the Proposed Amendments were approved on August 25, 2023. There were 

no substantive opposing views expressed with respect to this filing. The Proposed Amendments are to be 

effective when incorporated into the MGEX Rulebook and posted on its website, which will be at least 10 

business days following the date of this submission. 

If there are any questions regarding this submission, please contact me at (612) 321-7141 or 

cstuhlmann@mgex.com. Thank you for your attention to this matter.

Sincerely,

Carmen M. Stuhlmann

Associate Counsel

Enclosure
MINNEAPOLIS GRAIN EXCHANGE, LLC

400 South 4th Street | 130 Grain Exchange Building | Minneapolis, MN 55415

612-321-7101

mgex.com

EXHIBIT A

The following MGEX Bylaws and Rules are to be amended. Additions are underlined while deletions 

are marked through.

3.6.13. FRONT RUNNING PROHIBITED.

No Market Participant shall place an order or execute any transaction based on non-public information 

regarding an impending transaction by another Person in the same or related product, which is commonly 

known within the derivatives trading industry as “front running”.