SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-477

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 19, 2023 Filing Description: Modifications to the 

Deferred 30-Day Federal Fund 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

December 19, 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 Deferred 30-Day Federal Fund Futures Market Maker Program

CBOT Submission No. 23-477

Dear Mr. Kirkpatrick:

The Board of Trade of the City of Chicago, Inc. (“CBOT” or “Exchange”) hereby notifies the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) of modifications to the Deferred 30-Day Federal Fund Futures Market 

Maker Program (“Program”). The modifications to the Program will become effective on February 1, 2024.

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

overstruck.

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

Exchange Act (“CEA”). During the review, CBOT 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 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 CBOT rules includes prohibitions against fraudulent, non-competitive, 

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 CBOT rules. The 

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

CBOT 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 CBOT Submission No. 23-477 in any related 

correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

Deferred 30-Day Federal Fund Futures Market Maker Program

Program Purpose

The purpose of the Program is to improve liquidity in deferred Federal Funds futures by providing 

incentives to designated participants who satisfy quoting obligations. A more liquid contract benefits all 

participants in the market.

Product Scope

CBOT Deferred 30-Day Federal Fund Futures traded on Globex® (“Products”).

Eligible Participants

The Exchange may designate up to fifteen (15) participants in the Program. Participants must be CBOT 

members. New participants are required to submit a Bid Sheet to the Exchange which is used to 

determine eligibility. Exchange staff will use a variety of factors in determining whether or not a 

prospective market maker is selected to participate in the Program, including past performance in 

Deferred 30-Day Federal Fund futures and the ability to commit to and maintain at least the required 

quoting obligations. Notwithstanding the foregoing, the Exchange may, from time to time, add to or 

subtract from the factors listed above as it deems necessary. 

Program Term

Start date is February 1, 2008. End date is January 31, 2024 January 31, 2025.

Hours

Regular Trading Hours (RTH), 7:00AM – 4:00PM (CST).

Obligations

In order to be eligible to receive incentives, participants must select and comply with two (2) sets of 

Exchange-defined quoting obligations set forth in Quoting Buckets 1-6 below. Participants must select at 

least one (1) Quoting Bucket for outright contracts. Participants may also choose Quoting Bucket 7 for

Federal Fund Strips as a third obligation set. Participants must quote each of the obligations during 65% 

of RTH.

Quoting Bucket 1: Outrights in Months 6-9

Month Max Spread Min Quantity

Month 6 1.00 50

Month 7 1.00 50

Month 8 1.00 50

Month 9 1.00 50
Quoting Bucket 2: Outrights in Months 10-13

Month Max Spread Min Quantity

Month 10 1.00 40

Month 11 1.00 40

Month 12 1.00 40

Month 13 1.00 40

Quoting Bucket 3: Outrights in Months 14-17

Month Max Spread Min Quantity

Month 14 1.00 20

Month 15 1.00 20

Month 16 1.00 20

Month 17 1.00 20

Quoting Bucket 4: Spreads in Months 5-10

Max Spread Min Quantity

Months 5-6 0.50 150

Months 6-7 0.50 150

Months 7-8 0.50 150

Months 8-9 0.50 150

Months 9-10 0.50 150

Quoting Bucket 5: Spreads in Months 10-15

Max Spread Min Quantity

Months 10-11 1.00 125

Months 11-12 1.00 125

Months 12-13 1.00 125

Months 13-14 1.00 125

Months 14-15 1.00 125

Quoting Bucket 6: Spreads in Months 15-20

Max Spread Min Quantity

Months 15-16 1.00 50

Months 16-17 1.00 50

Months 17-18 1.00 50

Months 18-19 1.00 50

Months 19-20 1.00 50

Quoting Bucket 7: Federal Fund Strips

Max Spread Min Quantity

Year 1 FF Strip 0.75 15

Year 2 FF Strip 1.00 5

Extreme Events Clause: If 2-Year Treasury (Yield) CME Group Volatility Index (CVOL) is 120 180 or 

greater for at least three (3) days in a given calendar month, the obligations below may be implemented

across all Quoting Buckets. Participants will be given notice that the Extreme Events Clause has taken 

effect.

(i) Bid/Ask Spread: Increased by 2X 1.5X
If 2-Year Treasury (Yield) CVOL reaches or surpasses 240 on any day in a given calendar month, the 

Exchange may reduce the time-in-market obligations across all Quoting Buckets. The time-in-market 

reduction is subject to a floor of 20%. 

Notwithstanding the foregoing, the Exchange may further reduce the bid/ask spreads, sizes, or time-inmarket obligations based on ongoing evaluations of market conditions and volatility. Participants will be 

given notice that the Extreme Events Clause has taken effect.

Holiday Quoting Schedule: There will be no quoting obligations on the dates listed below. The Holiday 

Quoting Schedule may be adjusted by the Exchange. Participants will be given notice of any adjustments 

to the Holiday Quoting Schedule.

Date Name of Holiday

2/20/2023 Presidents’ Day

4/7/2023 Good Friday

5/29/2023 Memorial Day

6/19/2023 Juneteenth

7/4/2023 Independence Day

9/4/2023 Labor Day

10/9/2023 Columbus Day

11/10/2023 Veterans Day

11/23/2023 Thanksgiving

11/24/2023 Post-Thanksgiving

12/25/2023 Christmas 

1/1/2024 New Year’s 

1/15/2024 Birthday of Martin Luther King, Jr.

2/19/2024 Presidents’ Day

3/29/2024 Good Friday

5/27/2024 Memorial Day

6/19/2024 Juneteenth 

7/4/2024 Independence Day

9/2/2024 Labor Day

10/14/2024 Columbus Day

11/11/2024 Veterans Day

11/28/2024 Thanksgiving

11/29/2024 Post-Thanksgiving

12/24/2024 Christmas Eve

12/25/2024 Christmas

1/1/2025 New Year’s

1/20/2025 Birthday of Dr. Martin Luther King, Jr.

Incentives

Quoting Buckets 1-6 Fee Discounts: Upon meeting the quoting obligations, as determined by the 

Exchange, participants will receive fee discounts of $0.06 per side for all volume traded on Globex® in 

contract Months 6 and beyond.

Fee Credits: Participants meeting the obligations for two (2) Quoting Buckets and Quoting Bucket 7, as 

determined by the Exchange, will receive fee credits of $0.10 per side on Federal Fund futures strips 

volume, capped at $10,000 per month, per participant. 
Monitoring and Termination of Status

If the Exchange determines that a participant has not met its quoting obligations during two (2) calendar 

months over the course of the Program, but is within twenty percent (20%) of the time-in-market 

obligations, the participant will be eligible to receive the incentives for each applicable month.

If the Exchange determines that a participant has not met its quoting obligations during one (1) additional 

calendar month, the participant will be eligible to receive all incentives for that applicable month. 

Excluding the aforementioned time-in-market leniency, participants must meet quoting obligations for all 

subsequent months in order to continue to receive the incentives.

Upon utilizing the exceptions set forth above, participants that fail to meet quoting obligations in any 

additional month may be removed from the Program.