SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-296

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): July 14, 2023 Filing Description: Implementation of the 

Ether/Bitcoin Ratio 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: 
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

July 14, 2023

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 Ether/Bitcoin Ratio Futures Market Maker Program

CME Submission No. 23-296

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 Ether/Bitcoin Ratio Futures Market Maker Program

(“Program”). The proposed Program will become effective on July 31, 2023.

Exhibit 1 sets forth the terms of this Program. 

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

Exchange Act (“CEA”). 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. Exchange staff will monitor trading in the Program’s products in order 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 Program does not impact the Exchange’s order execution. 

Participants in the Program will be selected by CME staff using criteria as set forth 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 CME in which each participant will expressly agree to comply with, and 

be subject to, applicable regulations and Exchange rules. Additionally, 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.

CME certifies that this submission has been concurrently posted on the CME 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. 23-296 in any related correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachment: Exhibit 1
EXHIBIT 1

Ether/Bitcoin Ratio Futures Market Maker Program

Program Purpose 

The purpose of this Program is to encourage participants to support the launch and development of the 

product listed below. A more liquid contract on the central limit order book benefits all participants in the 

marketplace.

Product Scope

Ether/Bitcoin Ratio Futures (“EBR”) (“Product”).

Eligible Participants

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

the Program. 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 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 July 31, 2023. End date is January 31, 2024.

Hours

5:00PM CT – 4:00PM CT.

Obligations

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

the Product at predetermined bid/ask spreads and minimum quote sizes during a certain percentage of 

time-in-market.

Incentives 

Upon meeting all 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 retains 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.