SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-515 (2 of 2)

Organization: The Board of Trade of the City of Chicago, Inc. (“CBOT”)

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): December 12, 2023 Filing Description: Modifications to the 

CME/CBOT Asset Manager Fixed Income Incentive Program (“AMFIIP”)

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

December 12, 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: Modifications to the CME/CBOT Asset Manager Fixed Income Incentive Program 

CBOT Submission No. 23-515 (2 of 2)

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME”) and The Board of Trade of the City of Chicago, Inc. (“CBOT”) 

(collectively, the “Exchanges”) hereby notify the Commodity Futures Trading Commission (“CFTC” or “Commission”) 

of plans to modify the CME/CBOT Asset Manager Fixed Income Incentive Program (“Program”). The modifications to

the Program will become effective on January 1, 2024. 

Exhibit 1 sets forth the terms of this Program. Modifications appear below, with additions underscored and deletions 

overstruck. 

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

Commodity Exchange Act (“CEA”). During the review, the Exchanges’ 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 does not impact the Exchanges’ ability to perform its trade practice and market surveillance obligations

under the CEA. All participant account information will be disclosed to the Exchanges’ market regulation staff so that 

they can monitor all trading in the Program to prevent manipulative trading and market abuse. Additionally, the 

Exchanges have implemented systems to track Program participants’ obligations to ensure proper distribution of 

earned incentives. The incentives in the Program do not impact the Exchanges’ order execution. Participants in the 

Program will be selected by the Exchanges’ staff using criteria as further stated in Exhibit 1. Chapter 4 of the 

Exchanges’ rules includes prohibitions against fraudulent, non-competitive, unfair, or abusive practices. All 

participants must execute an application with the Exchanges in which each participant will expressly agree to comply 

with and be subject to, applicable regulations and Exchanges’ rules. The Program is subject to the Exchanges’ record 

retention policies which comply with the CEA. 

The Exchanges certify that the Program complies with the CEA and the regulations thereunder. There were no 

substantive opposing views to this Program.

The Exchanges certify that this submission has been concurrently posted on the Exchanges’ 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 CBOT Submission No. 23-515 in any related 

correspondence.

Sincerely, 

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel

Attachment: Exhibit 1
EXHIBIT 1

CME/CBOT Asset Manager Fixed Income Incentive Program

Program Purpose

The purpose of this Program is to enhance liquidity in the products listed below that are traded on the 

CME Globex Platform and on the CME trading floor. A more liquid contract benefits all participants in the 

market.

Product Scope

All CME & CBOT interest rate futures and options traded on the CME Globex Platform and on the CME

trading floor (“Products”).

Eligible Participants

There is no limit to the number of participants. All participants must be asset managers. Participants may 

be members of CME or CBOT or non-members. 

Program Term 

Start date is August 16, 2011. End date is December 31, 2023 December 31, 2024.

Obligations

Participants may not participate in any other interest rate future and/or interest rate option fee incentive 

program while actively in the Program.

Only trades made through accounts that are managed/controlled by participant may receive incentives for 

the Products under the Program. 

This Program does not require participant Tag50 registration in the Exchange Fee System.

Incentives

Discounted Fee Incentive. During each calendar quarter, participants may qualify to receive tiered 

reduced all-in fee rates for the Products, the applicable tier being dependent on each participant’s open 

interest in the Products and average daily volume in the Products during the quarter (“Qualifying 

Quarter”). 

The fee rate for which a participant qualifies in a given Qualifying Quarter will be applied to trades made

by the participant for qualifying accounts under the participant’s management during the three (3) month 

period immediately following the applicable Qualifying Quarter. 

Monitoring and Termination of Status

The Exchanges shall monitor trading activity and shall retain the right to revoke participant status in the 

Program if it concludes from its review that a participant is not complying with obligations.