CX Contract Rule Filing 

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Cantor Futures Exchange

New Contract Submission 

March 17, 2015

1. The text of the terms and conditions of the CANTOR FUTURES EXCHANGE

DIGITAL FLEX SWAPS SILVER CONTRACT (”Contract”) and all related rules are 

attached.

2. The intended listing date is April 20, 2015

3. The certification of compliance with the Act and regulations thereunder is attached.

4. A certification that Cantor Futures Exchange that this submission was posted on the 

Cantor Futures Exchange, L.P. website the day of its submission to the Commission is 

attached

5. Confidential Treatment is not requested. 

CONCISE EXPLANATION AND ANALYSIS OF THE CONTRACT’S 

COMPLIANCE WITH APPLICABLE CORE PRINCIPLES AND COMMISSION 

REGULATIONS

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended, and 

Commodity Futures Trading Commission (“Commission”) Cantor Futures Exchange, L.P 

(“Cantor Exchange” or the “Exchange”) hereby notifies the Commission of the Exchange’s 

certification that it will list for the Contract for trading. 

As set forth above, Cantor Exchange intends to list the Contract as of April 20, 2015. 

The terms and conditions for the new contracts are contained in new Exchange rule IX2100. Such new rule language including terms and conditions is provided in this submission as 

Appendix A.

The Exchange has received no opposing views regarding introduction of the Contract and 

respectfully submits the below narrative describing the contract, including data and information 

to support the Contract's terms and conditions, as set by the Exchange:

Appendix C to Part 38—Demonstration of Compliance That a Contract Is Not Readily 

Susceptible to Manipulation

(4) Options on Physicals Contracts. (i) Under the Commission’s regulations, the term 

‘‘option on physicals’’ refers to option contracts that do not provide for exercise into an 

underlying futures contract. Upon exercise, options on physicals can be settled via physical 

delivery of the underlying commodity or by a cash payment. Thus, options on physicals 
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raise many of the same issues associated with trading in futures contracts regarding 

adequacy of deliverable supplies or acceptability of the cash settlement price series. In this 

regard, an option that is cash settled based on the settlement price of a futures contract 

would be considered an ‘‘option on physicals’’ and the futures settlement price would be 

considered the cash price series.

(ii) In view of the above, acceptable practices for the terms and conditions of options on 

physicals contracts include, as appropriate, those practices set forth above for physicaldelivery or cash-settled futures contracts plus the practices set forth for options on futures 

contracts.

As required by Appendix C, the following analysis with respect to the Contracts, which are 

options on physicals, sets forth those relevant sections of Appendix C that pertain to cash-settled 

futures contracts and to options.

(1) A narrative describing the contract, including data and information to support the 

contract's terms and conditions, as set by the designated contract market.

The Contract is based on spot silver price quotes. The cash settlement price is based on a 

price index determined by the Exchange (the “Index”). Contract Rule IX-2100(b) 

explains the Index calculation methodology in detail. 

The Index price is derived from the latest eight spot bids and spot offers of independent 

third party market participants. Cantor Exchange calculates the Index every half-second 

and broadcasts this value to market participants.

Cantor Exchange confirms that the Index remains representative of spot market value by 

continuously monitoring and comparing it with other widely accepted values for the 

silver spot price provided by major quote vendor systems. As provided in Rule IX2100(b) the calculated Index value will be replaced by the silver spot price provided by 

major quote vendors any time the Exchange determines that the Index is best represented 

by that price, for example, if there were less than eight bids and offers received within an 

appropriate interval based on market conditions. 

Contracts are listed for daily expiration, with an expiration the following day at 4:00pm. 

Participants may also request intra-day expirations by electronic means or by agreement 

with the Exchange.

Final cash settlement of the contract is digital in nature, such that if at the final settlement 

time the Silver Index is above the strike price then each purchaser shall be paid one 

dollar; if at final settlement time the Silver Index is below the strike price, then each 

seller shall be paid one dollar; if at final settlement time the Silver Index is equal to the 

strike price, then each purchaser and each seller shall receive fifty cents. The settlement 

obligation does not vary based upon the amplitude by which the price at expiration 

exceeds the strike price. 
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2) A Detailed cash market description for physical and cash-settled contracts. Such 

descriptions should be based on government and/or other publicly-available data whenever 

possible and be formulated for both the national and regional/local market relevant to the 

underlying commodity.

The Contract is based upon a price Index that is calculated with reference to the global 

spot price of silver. The London Bullion Market Association cleared in excess of 7 

million ounces per day, equating to a daily cleared value in excess of US$100 million. 

Additionally, silver and silver futures are traded on numerous regulated exchanges 

throughout the world.

Spot silver trading is conducted around the clock in major bullion centers with Hong 

Kong, Zurich, London, New York and Chicago being the primary locations.

The following narrative, in chart format, details the particular contract terms and how 

they comply with Core Principle 3 and Commission Rule 38.200.

(c) Futures Contracts Settled by Cash Settlement. (1) Cash settlement is a method of 

settling certain futures or option contracts whereby, at contract expiration, the contract is 

settled by cash payment in lieu of physical delivery of the commodity or instrument 

underlying the contract. An acceptable specification of the cash settlement price for 

commodity futures and option contracts would include rules that fully describe the 

essential economic characteristics of the underlying commodity (e.g., grade, quality, weight, 

class, growth, issuer, maturity, source, rating, description of the underlying index and 

index's calculation methodology, etc.), as well as how the final settlement price is

calculated. In addition, the rules should clearly specify the trading months and hours of 

trading, the last trading day, contract size, minimum price change (tick size) and any 

limitations on price movements (e.g., price limits or trading halts).

Please see the narrative above which sets forth an explanation of the commodity 

underlying the Index and the calculation of the Index. The following chart sets forth each 

of the Contract’s terms and conditions with a narrative explanation of how the term or 

condition is consistent with cash market practice and Commission rules. 

Term or condition 

Rule number 

of identical 

approved 

provision, if 

any1

Explanation as to consistency with, or reason 

for variance from, cash market practice

1. Commodity 

characteristics (e.g., grade, 

quality, weight, class, 

growth, issuer, maturity, 

source, rating, etc.)

IX-2100(b) The commodity is a precious metal. The Silver

Index is derived from dealable bids or offers of 

independent third-party spot market participants 

received by the Exchange which embodies the

relationship between the same.
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2. Delivery months, noting 

any cyclical variations in 

trading activity that may 

affect the potential for 

manipulating the cash 

settlement price

IX-2100(d) Contracts are settled to the Silver Index which 

consists of at least 8 different bids and offers 

gathered from a wide array of spot market 

participants. Additionally, Cantor Exchange may 

use values obtained from outside market data 

providers in determining the settlement price. 

Therefore the settlement price will always be 

representative of the silver spot price 

3. Last trading day Each contract expires at or before 4PM New York 

time each trading day.

4. Contract size IX-2100(e) One dollar.

5. Minimum price change 

(tick)

IX-2100(f)(ii) The minimum price change is $0.01 and is 

designed to result in liquid trading with

competitive bid/offer spreads.

6. Daily price limit 

provisions, relative to cash 

market price movements

IX-2100(f)(i) Contracts may not trade above a price of one 

dollar, which is also the maximum cash settlement 

value of the Contract. 

2) Cash settled contracts may be susceptible to manipulation or price distortion. In 

evaluating the susceptibility of a cash-settled contract to manipulation, a designated 

contract market should consider the size and liquidity of the cash market that underlies the 

listed contract in a manner that follows the determination of deliverable supply as noted 

above in (b)(1). In particular, situations susceptible to manipulation include those in which 

the volume of cash market transactions and/or the number of participants contacted in 

determining the cash-settlement price are very low. Cash-settled contracts may create an 

incentive to manipulate or artificially influence the data from which the cash-settlement 

price is derived or to exert undue influence on the cash-settlement price's computation in 

order to profit on a futures position in that commodity. The utility of a cash-settled 

contract for risk management and price discovery would be significantly impaired if the 

cash settlement price is not a reliable or robust indicator of the value of the underlying 

commodity or instrument. Accordingly, careful consideration should be given to the 

potential for manipulation or distortion of the cash settlement price, as well as the 

reliability of that price as an indicator of cash market values. Appropriate consideration 

also should be given to the commercial acceptability, public availability, and timeliness of 

the price series that is used to calculate the cash settlement price. Documentation 

demonstrating that the settlement price index is a reliable indicator of market values and 

conditions and is commonly used as a reference index by industry/market agents should be 

provided. Such documentation may take on various forms, including carefully documented 

interview results with knowledgeable agents.
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As explained above, the Exchange has taken into account the characteristics of the spot 

precious metals market in determining the means by which it will calculate the Index 

value. As discussed above, the precious metal spot markets are liquid, deep and 

relatively transparent. Cantor Exchange will calculate the Index using the Olympic 

average methodology. As set forth above, the Silver Index will be calculated by the 

Exchange by continuously taking the last eight bid and the last eight offer spot quotations 

for each silver spot quote received by the Exchange, then removing the two highest bids 

and two highest offers and removing the two lowest bids and two lowest offers received 

by the Exchange from recognized distributors of precious metals price information or 

dealable quotations from independent third-party spot market participants, then taking the 

midpoint. The Exchange then compares its Index value against the values other price 

feeds that track spot precious metal prices in order to ensure the accuracy of its Index. 

Based on the above, the Exchange believes that the Index that it calculates will be a

robust and reliable indicator of the value of spot currency and will provide an acceptable 

and widely accepted underlying for this contract.

(3) Where an independent, private-sector third party calculates the cash settlement price 

series, a designated contract market should consider the need for a licensing agreement 

that will ensure the designated contract market's rights to the use of the price series to 

settle the listed contract.

Not applicable; the Index is calculated by Cantor Exchange.

(i) Where an independent, private-sector third party calculates the cash settlement price 

series, the designated contract market should verify that the third party utilizes business 

practices that minimize the opportunity or incentive to manipulate the cash-settlement 

price series. Such safeguards may include lock-downs, prohibitions against derivatives 

trading by employees, or public dissemination of the names of sources and the price quotes 

they provide. Because a cash-settled contract may create an incentive to manipulate or 

artificially influence the underlying market from which the cash-settlement price is derived 

or to exert undue influence on the cash-settlement computation in order to profit on a 

futures position in that commodity, a designated contract market should, whenever 

practicable, enter into an information-sharing agreement with the third-party provider 

which would enable the designated contract market to better detect and prevent 

manipulative behavior.

Not applicable.

(ii) Where a designated contract market itself generates the cash settlement price series, the 

designated contract market should establish calculation procedures that safeguard against 

potential attempts to artificially influence the price. For example, if the cash settlement 

price is derived by the designated contract market based on a survey of cash market 

sources, the designated contract market should maintain a list of such entities which all 

should be reputable sources with knowledge of the cash market. In addition, the sample of 
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sources polled should be representative of the cash market, and the poll should be 

conducted at a time when trading in the cash market is active.

The final settlement relies upon dealable price quotes that are continuously made 

available from institutional independent third-party spot market participants. Dealable 

prices are superior to surveys because the quotes used represent levels at which parties 

are willing to enter into spot transactions. Furthermore, the rules provide for alternative 

calculation at the discretion of the Exchange in the event that dealable silver spot quotes 

are unavailable due to market conditions. 

(iii) The cash-settlement calculation should involve computational procedures that 

eliminate or reduce the impact of potentially unrepresentative data.

As noted above, the Exchange automatically discards the two highest and lowest bids and 

offers from the Index calculation. This methodology ensures that inadvertent or 

intentional attempts by any single market participant to influence the Index calculation 

will have no impact. Furthermore, the Exchange does not always use dealable quotes 

from the same providers, so it is impossible for any market participant to know if their 

quote is being used in the calculation of the Index. 

(iv) The cash settlement price should be an accurate and reliable indicator of prices in the 

underlying cash market. The cash settlement price also should be acceptable to 

commercial users of the commodity contract. The registered entity should fully document 

that the settlement price is accurate, reliable, highly regarded by industry/market agents, 

and fully reflects the economic and commercial conditions of the relevant designated 

contract market.

The Index is calculated by reference to dealable quotes for spot market precious metals

transactions that are available to the Exchange. These quotes are being offered by 

numerous spot market participants that transact regularly and are active in the spot 

precious metals market. Because the Exchange uses only dealable bids or offers, these 

quotes represent accurate values of the underlying spot commodity. The Exchange

confirms that its Index tracks other silver spot market prices to ensure the reliability of 

the Index values.

(v) To the extent possible, the cash settlement price should be based on cash price series 

that are publicly available and available on a timely basis for purposes of calculating the 

cash settlement price at the expiration of a commodity contract. A designated contract 

market should make the final cash settlement price and any other supporting information 

that is appropriate for release to the public, available to the public when cash settlement is 

accomplished by the derivatives clearing organization. If the cash settlement price is based 

on cash prices that are obtained from non-public sources (e.g., cash market surveys 

conducted by the designated contract market or by third parties on behalf of the 

designated contract market), a designated contract market should make available to the 

public as soon as possible after a contract month's expiration the final cash settlement price 
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as well as any other supporting information that is appropriate or feasible to make 

available to the public.

As discussed above, the market for precious metals trading is perhaps the most liquid and 

transparent in the world. Accordingly, the Index values will be readily comparable to 

pricing information on the value of spot precious metals that is widely disseminated by a 

number of reputable price reporters. In addition, the Exchange will disseminate the Index 

on a continuing basis to its members and to the public.

(H) Speculative Limits: Specific rules and policies for speculative position limits are set 

forth in part 150 and/or part 151, as applicable, of the Commission's regulations.

(I) Reportable Levels: Refer to § 15.03 of the Commission's regulations.

Terms and Conditions Related to Speculative Limits.

Speculative 

limit Standard

Level

(exchange rule)

1. Spot, single 

month, all 

months

Must be no greater than 

necessary to minimize the 

potential for manipulation or 

distortion of the contract's or 

the underlying commodity's 

price.

The Rules provide for a Position Accountability 

level of 10,000 contracts, combined, in the 

Contract. See CFTC Rule 150.5.

4. Reporting 

level

Equal to or less than levels 

specified in CFTC rule 15.03.

The exchange and clearing house have available 

complete information with respect to the positions 

of each participant, and therefore are able to 

report complete position information to a Swaps 

Data Repository or to the Commission to the 

extent required.

5. Aggregation 

rule

Same as CFTC rule 150.5(g) 

or previously approved 

language.

Yes.

Conclusion

As indicated by the above discussion and analysis, the cash price series for the Index is reliable, 

acceptable and timely and is not readily subject to manipulation. The Index will be calculated by 

Cantor Exchange based upon dealable bids and offers by third party market participants for spot 

precious metals transactions available to the Exchange. The data is collected in a highly 

automated manner and generally is recognized as reliable by cash market participants. In light of 

the depth and liquidity of the foreign precious metals spot market and the high transparency of 
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spot market transactions, Cantor Exchange believes that the quotes upon which the Index is 

calculated are unlikely to be readily subject to manipulation.
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CERTIFICATIONS PURSUANT TO SECTION 5c OF THE COMMODITY EXCHANGE 

ACT, 7 U.S.C. §7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE 

40.2, 17 C.F.R. §40.2

I hereby certify that the SILVER DIGITAL FLEX SWAPS CONTRACT complies with the 

Commodity Exchange Act, 7 U.S.C. §1 et seq. and regulations thereunder.

_________________________

By: Manavinder S. Bains

Title: Counsel & Chief Regulatory Officer

Dated: March 17, 2015

I hereby certify that a copy of this filing was posted on the Cantor Futures Exchange, L.P. 

website the day of its submission to the Commission.

_________________________

By: Manavinder S. Bains

Title: Counsel & Chief Regulatory Officer

Dated: March 17, 2015
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CANTOR FUTURES EXCHANGE, L.P.

CHAPTER IX

CONTRACTS

IX-2100 SILVER DIGITAL FLEX SWAPS CONTRACT

(a) Scope and Underlying

These Contract Rules will govern the trading on the Cantor Futures Exchange, 

L.P. (the “Exchange”) of the / US DOLLAR DIGITAL FLEX SWAPS CONTRACT (the 

“Contract”). Clearing of the Contract will be governed by the rules of the Cantor Clearinghouse, 

L.P. (the “Clearinghouse”). These Contract Rules are established pursuant to and constitute 

“Contract Rules” under Rule I-5 of the Rules of the Exchange and constitute “Contract Rules” 

Under Rule I-7 of the Rules of the Clearinghouse. Capitalized terms used, but not defined 

herein, have the meanings ascribed to them in the Rules of the Exchange or the Rules of the 

Clearinghouse, as applicable.

(b) Calculation of the Index

The Silver Index will be calculated by the Exchange continuously taking the last 

eight bid and the last eight offer spot quotations for each silver spot price received by the 

Exchange, then removing the two highest bids and two highest offers and removing the two 

lowest bids and two lowest offers received by the Exchange from recognized distributors of 

precious metals price information or dealable quotations from independent third-party spot 

market participants, then calculating the arithmetic mean of the remaining eight values and 

rounding to the third decimal place. Notwithstanding the above, the Exchange may determine the 

Index value, in its sole and absolute discretion, using the best available indicative silver spot 

prices available from recognized distributors of precious metals price information. 

(c) Trading Hours for the Contracts

(i) Except as otherwise posted on the Exchange website, , tradable contracts 

under the Contract will be open for trading Sunday 6:30 PM ET until Friday 4:00 PM ET. No 

trading in these contracts shall occur between the hours of 4:00 PM ET and 6:30 PM ET on any 

Exchange Trading Day.

(ii) Abbreviated holiday trading schedules may apply and will be posted on 

the Exchange website.

(d) First Time of Trading, Last Time of Trading for the Contract

(i) Tradable contracts under the Contracts shall be listed for trading for each 

Exchange Trading Day except as otherwise published on the Exchange website and shall begin 

trading at 6:30 PM ET and shall cease trading at 4:00 PM ET on that Exchange Trading Day.
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(ii) Tradable contracts under the Contracts may also be listed in response to 

requests received by the exchange from Participants. All such requests shall include the final 

settlement time and the strike price for the contract. Contracts become tradable immediately 

upon listing by the Cantor Direct System, and remain tradable until the final settlement time.

(e) Final Settlement for the Contract

(i) Each open position in tradable contracts under the Contracts will be Cash 

Settled such that if at the final settlement time the Silver Index is above the strike price then each 

purchaser shall be paid one dollar; if at final settlement time the Silver Index is below the strike 

price, then each seller shall be paid one dollar; if at final settlement time the Silver Index is equal 

to the strike price, then each purchaser and each seller shall receive fifty cents.

(f) Contract Price Limits and Minimum Increment for the Contract

(i) There shall be no trading in tradable contracts under the Contracts at a

price of more than one dollar.

(ii) The minimum trading increment of each tradable contract under the 

Contract is one cent.

(g) Position Accountability Levels for the Contract

The position accountability level shall be 10,000 net short or net long contracts 

combined in tradable contracts under the Contract.

(h) Original Margin for Contract

(i) Original Margin shall be 100% of the at-risk amount for both buyers and 

sellers tradable contracts under the of the Contract.

(ii) As required by rule IX-2100(h)(i), buyers of Contracts shall post the 

purchase price as Original Margin; sellers of tradable contracts under the Contracts shall post 

one dollar minus the sale price as Original Margin.