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November 1, 2023

BY ELECTRONIC FILING

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

1155 21st Street, NW

Washington, DC 20581

Re: Cboe Clear Digital, LLC Rule Certification Submission Number CCD-2023-06C

Dear Mr. Kirkpatrick:

Cboe Clear Digital, LLC (“CCD” or “Clearinghouse”), a registered derivatives clearing 

organization (“DCO”) under the Commodity Exchange Act, as amended (the “Act”), hereby 

submits, pursuant to §40.6(a) of the regulations promulgated by the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) amendments to the Exchange and Clearing Fee Schedule 

in connection with fees for financially-settled margined futures on digital assets (“Amendment”). 

The Exchange and Clearing Fee Schedule (“Fee Schedule”)1 will become effective on November 

16, 2023 (“Effective Date”). CCD intends to begin clearing financially-settled margined futures 

on digital assets on a date after the Effective Date to be announced by CCD through the issuance 

of a notice.

The Fee Schedule is being revised to, among other things, establish clearing fees associated with 

transactions in financially-settled margined futures contracts2to be launched by Cboe Digital 

Exchange, LLC (“CDE” or the “Exchange”), a registered designated contract market (“DCM”),

which will be cleared by CCD. The text of the clearing fees associated with the proposed Fee 

Schedule is appended as Exhibit A.3

The clearing fees reflected in the Fee Schedule will be applied to Clearing Members of CCD, per 

transaction per contract. As shown in Exhibit A, there will be two separate categories of clearing 

fees applicable to Clearing Members: (i) Delivery Fees and (ii) Clearing, Position Transfer, and 

1 The Fee Schedule is located on the Cboe Digital website at https://www.cboedigital.com/product/futures-fees/. 

2 Financially-settled bitcoin futures (“FBT”) on a margin basis and financially-settled Ether futures (“FET”) on a 

margin basis. CCD intends to begin clearing physically-settled bitcoin futures (“BTC”) on a margin basis and

physically-settled Ether futures (“ETH”) on a margin basis at a time following the launch of FBT and FET, and 

intends to submit a separate rule certification in connection with clearing fees for BTC and ETH.

3 Please note that Exchange fees assessed by the DCM are omitted from Exhibit A and will be submitted under a 

separate self-certification to the CFTC from Cboe Digital Exchange, LLC.
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Day 2 Give-Up Fees. Additionally, the Amendment clarifies that a Clearing Member is an FCM 

Clearing Member of CCD and a Trading Privilege Holder of the Exchange.

CCD has assessed the amendments to the Fee Schedule in connection with clearing fees for 

financially-settled margined futures products and its compliance with applicable provisions of the 

Act, including the Commission’s Regulations and DCO Core Principles. CCD has identified the 

following Core Principles as potentially being impacted:

• Core Principle L (Public Information) - As required by Core Principle L, CCD will publish 

the Fee Schedule on the Cboe Digital website to ensure that market participants have been 

advised of the modifications, and 

• Core Principle B (Financial Resources) - The Fee Schedule will not impact CCD’s ability 

to discharge its financial, operational, or managerial responsibilities as a DCO.

CCD believes that the impact of the proposed Fee Schedule will be beneficial to the public and 

market participants. CCD is not aware of any substantive opposing views to the Fee Schedule. 

CCD hereby certifies that proposed Fee Schedule complies with the Act and the Commission’s 

regulations thereunder. 

Concurrent with the filing of this submission, CCD will post a notice of pending certification with 

the Commission and a copy of this submission on the Cboe Digital website 

(https://www.cboedigital.com/regulation/exchange-notices/). 

Questions regarding this submission may be directed to Katherine Kirkpatrick at (312) 786-7431

and Rebecca Tenuta at (312) 786-7068. Please reference our submission number CCD-2023-06C

in any related correspondence.

Sincerely, 

/s/ Katherine Kirkpatrick

Katherine Kirkpatrick

Chief Legal Officer, Cboe Digital

kkirkpatrick@cboe.com
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Exhibit A

The Amendments, marked to show additions in underlined text and deletions in stricken text, 

consists of the following:

* * * * *

Fee Categories

Fees will be applied to participants based upon the following 3 categories:

Category* Description

Direct Individual or Firm Customer A Customer of a Trading Privilege Holder

Professional Trading Firm Proprietary Firm A Professional Trading Firm is an entity that 

certifies they have substantial trading and 

exchange connectivity management 

experience A Trading Privilege Holder that 

trades on behalf of its own account. 

Market Maker A Market Maker is a Professional Trading 

Firm Trading Privilege Holder that has entered 

into market making agreement with Cboe 

Digital and meets specific metrics on a 

monthly basis.

Clearing Member An FCM Clearing Member of Cboe Clear 

Digital and a Trading Privilege Holder 

Spot Member A Trading Privilege Holder that is also a 

member of the Cboe Digital spot market. 

* All categories of users will be required to enter into user agreements with Cboe Digital and will 

be required to accept certain risks and disclosures. Cboe Digital reserves the right to modify the 

content of this Rate Card.

Exchange and Clearing Fees

ParticipantsTrading Privilege Holders pay are assessed fees and rebates on each transaction 

executed on the Exchange based upon the rates below for each category. These fees and rebates

are chargedassessed per contract in USD. Fees and incentives are effective from December 17, 

2019Effective as of November 16, 2023.

Futures (per contract per 

side)*

Direct Clearing Rate** FCM Client Rate**

Individual | Firm 0 0

Professional Trading Group 0 0

Market Maker 0 0

Deliveries 0 0
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* Fees contained in this table are exclusive of fees which may be charged by futures commission 

merchants for non-direct clearing clients.

**Fees are waived.

Fee Description Product

FBT FET

* * * * *

Clearing Member Delivery Fee $0.25 $0.25

Clearing Member Clearing, Position 

Transfer, & Day 2 Give-up Fee

$0.02 $0.02

* * * * *