SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 24-068

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): January 11, 2024 Filing Description: Implementation of the 

Options on S&P 500 Annual Dividend Futures Market Maker 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 11, 2024

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 Options on S&P 500 Annual Dividend Futures Market Maker 

Program

CME Submission No. 24-068

Dear Mr. Kirkpatrick:

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

Commission (“CFTC” or “Commission”) of plans to implement the Options on S&P 500 Annual Dividend Futures 

Market Maker Program (“Program”). The proposed Program will become effective on January 29, 2024.

Exhibit 1 sets forth the terms of this 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 will not impact the Exchange’s ability to perform its trade practice and market surveillance obligations

under the CEA and the Exchange’s market regulation staff 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’ obligations to ensure proper distribution of earned incentives. The incentives in the Program do not 

impact the Exchange’s order execution. Participants in the Program will be selected by Exchange staff using criteria 

as further stated in Exhibit 1. Chapter 4 of the Exchange’s rules includes prohibitions against fraudulent, noncompetitive, 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 the 

Exchange’s rules. The Program is subject to the Exchange’s record retention policies which comply with the CEA. 

The Exchange 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 CME Submission No. 24-068 in any related correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel

Attachment: Exhibit 1
EXHIBIT 1

Options on S&P 500 Annual Dividend Futures Market Maker Program

Program Purpose 

The purpose of this Program is to support the launch and development of the product listed below. The 

resulting increase in liquidity on the central limit order book benefits all participant segments in the 

market.

Product Scope

Options on S&P 500 Annual Dividend Index Futures (“SDA” or the “Product”).

Eligible Participants

CME may designate up to seven (7) participants in the Program. Participants may be CME members or 

non-members. Prospective participants are required to submit an application/bid sheet to the Exchange 

as part of a competitive selection 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 similar products. The Exchange may, from time to 

time, add or subtract from the aforementioned requirements as it deems necessary.

Program Term 

Start date is January 29, 2024. End date is July 31, 2024.

Hours

8:30AM – 2:45PM CT.

Obligations

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

predetermined average bid/ask spreads and minimum quote sizes during a certain percentage of time-inmarket.

Incentives 

Upon meeting the obligations, as determined by the Exchange, participants will 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.