Via Portal Submission August 25, 2023

 MGEX Submission No. 23-47

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 Risk Manual & Exhibit A

Dear Mr. Kirkpatrick:

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

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

(“MGEX” or “Exchange”) hereby submits this self-certification of certain amendments to 

MGEX’s Risk Management Principles Reference Manual (“Risk Manual”) & Exhibit A –

Bitnomial Bitcoin Futures & Options Margin Methodology (“Exhibit A”). MGEX has 

respectfully requested confidential treatment for such amendments to the Risk Manual

and Exhibit A, which are being submitted concurrently with this submission. The 

Exchange intends to implement the amendments ten business days following the filing of 

this submission. 

Overview of Amendments

MGEX has amended its Risk Manual and its accompanying Exhibit A, as shown in the 

attachment accompanying this submission, to make necessary updates and additions 

pertaining to the clearing of Bitnomial Options on Bitcoin Futures. Specifically, the 

amendments add new language to the Risk Manual identifying the Options on Bitcoin 

Futures as a product included within MGEX stress tests. With respect to Exhibit A, the 

amendments add new descriptions and labeling of Futures Scan Range, Volatility Scan 

Range, and Short Option Minimum related to Options on Bitcoin Futures.
MINNEAPOLIS GRAIN EXCHANGE, LLC

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

612-321-7101

mgex.com

DCO Core Principles

In connection with updating its Risk Manual and Exhibit A, the Exchange has reviewed 

the core principles for derivatives clearing organizations (“DCO Core Principles”) and has 

determined that the amendments comply with the requirements of such principles. During 

the review, MGEX identified the following DCO Core Principle as potentially being 

impacted:

• DCO Core Principle D – Risk Management: CFTC Regulation 39.13 requires 

DCOs to possess certain risk management tools and procedures. These changes 

adding new language to the Risk Manual and Exhibit A related to the clearing of 

Bitnomial Options on Bitcoin Futures serve to update the Exchange’s risk 

management tools and procedures, and as such, the amendments are consistent 

with the requirements of Core Principle D, CFTC Regulations 39.13 and 39.36.

MGEX hereby certifies that the amendments to its Risk Manual and Exhibit A comply with 

the CEAct and the CFTC regulations promulgated thereunder. The Exchange is not 

aware of any substantive opposing views expressed regarding the amendments or this 

filing. MGEX further certifies that, concurrent with this filing, a copy of the submission 

was posted on the Exchange website at the following link: 

http://www.mgex.com/regulation.html. If there are any questions regarding this 

submission, please contact me at (612) 321-7176 or jkrause@mgex.com. Thank you for 

your attention to this matter.

Sincerely, 

James D. Krause

Associate Corporate Counsel, DCO & Int’l