SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 21-108 (2 of 2)

Organization: Commodity Exchange, Inc. (“COMEX”)

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 02/19/21 Filing Description: Increase of Spot Month Position 

Limits of NYMEX and COMEX Physically-Delivered Metals Futures and Related

Contracts 

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: 

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: See filing.

Rule Numbers: See filing.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

February 19, 2021

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581 

Re: CFTC Regulation 40.6(a) Certification. Increase of Spot Month Position Limits for 

NYMEX and COMEX Physically-Delivered Metals Futures and Related Contracts. 

COMEX Submission No. 21-108 (2 of 2) 

Dear Mr. Kirkpatrick:

Pursuant to Commodity Futures Trading Commission (“CFTC” or “Commission) Regulation 40.6(a), New 

York Mercantile Exchange, Inc. (“NYMEX”) and Commodity Exchange, Inc. (“COMEX”) (collectively, the 

“Exchanges”) are certifying an increase to the spot month position limits of NYMEX and COMEX physicallydelivered metals futures contracts in Exhibit 1. below and their related contracts as more specifically 

described in Appendix A and Appendix B attached, (collectively, the “Contracts”) commencing with the April

2021 contract month and beyond (collectively, the “Rule Amendments”), effective concurrent with the March 

15, 2021 effective date for the CFTC’s final rule on Position Limits for Derivatives (“Final Rule”). 

In a separate but related matter, and in a further effort to comply with the CFTC’s Final Rule, NYMEX and 

COMEX are requesting review and approval of amendments to NYMEX/COMEX Rules 559. (“Position 

Limits and Exemptions”) and 562. (“Position Limit Violations”) (See Submission No. 21-069 dated January 

27, 2021.)

Commencing with the April 2021 contract and beyond, for the physically delivered NYMEX and COMEX 

metals listed in the table below, the spot month position limit will be applied and enforced separately for 

futures and for deliveries during the spot month.

Exhibit 1

(additions underscored; deletions struck through)

Contract 

Title

Commodity 

Code

Rule 

Chapter

Initial SpotMonth Limit (In 

Net Futures 

Equivalents) 

Leg (1)

Spot-Month Position 

Comprised of Futures 

and Deliveries (for 

contracts up to and 

Including March 2021)

Spot Month Net 

Delivery Limit 

(for contracts 

commencing 

with April 2021 

and beyond)

NYMEX

Palladium 

Futures 

PA 106 50 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

50
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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Platinum 

Futures 

PL 105 500 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

500

COMEX

Gold Futures GC 113 6,000 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

6,000

Silver Futures SI 112 1,500 3,000 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

3,000

Copper 

Futures

HG 111 1,000 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

1,000

Aluminum 

Futures

ALI 107 150 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

150

Lead Futures LED 187 10 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

10

Zinc Futures ZNC 186 25 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

25

Gold Kilo 

Futures

GCK 114 1,000 For position limit 

purposes, spot month 

position comprised of 

futures and deliveries.

1,000

The Position Limit, Position Accountability and Reportable Level Table and Header Notes located in the 

Interpretations and Special Notices Section of Chapter 5 of the COMEX Rulebook (the “Table”) will be 

amended to reflect aforementioned changes. Appendix A and Appendix B (effective March 15, 2021 and 

March 30, 2021, respectively) provide the Table with additions underscored and deletions struck through. 

COMEX is also providing an updated analysis of deliverable supply in connection with the increased 

position limits for the Silver Futures contract (see Appendix C provided under separate cover).

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

the Commodity Exchange Act (“Act”) and identified that Rule Amendments may have some bearing on the 

following Core Principles.

• Contracts not Readily Subject to Manipulation: The Contracts are not readily subject 

to manipulation due to the deep liquidity and robustness in the underlying physical markets.

• Position Limitations or Accountability: The speculative position limits for the Contracts 

as demonstrated in this submission are consistent with the Commission’s guidance.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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• Availability of General Information: The information contained herein will be 

disseminated to the marketplace via Market Surveillance Notice. The Exchanges will 

publish information on the Contracts’ specifications on its website, together with daily 

trading volume, open interest, and price information.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.6(a), the Exchanges hereby certify that the

Rule Amendments comply with the Act, including regulations under the Act. There were no substantive 

opposing views to this proposal.

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 addition information regarding this submission, please contact the undersigned at (212) 

299-2200 or via e-mail at CMEGSubmisisonInquiry@cmegroup.com.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachments: Appendix A - Position Limit, Position Accountability, and Reportable Level Table in Chapter

 5 of the NYMEX/COMEX Rulebook (attached under separate cover) (effective 

 March 15, 2021)

 Appendix B - Position Limit, Position Accountability, and Reportable Level Table in Chapter

 5 of the NYMEX/COMEX Rulebook (attached under separate cover) (effective 

 close of business March 30, 2021)

 Appendix C - Analysis of Deliverable Supply – Silver Futures (attached under separate

 cover)
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Appendix A

NYMEX/COMEX Rulebook

Chapter 5

(“Trading Qualifications and Practices”)

Position Limit, Position Accountability, and Reportable Level Table 

(attached under separate cover)

(effective March 15, 2021)

Appendix B

NYMEX/COMEX Rulebook

Chapter 5

(“Trading Qualifications and Practices”)

Position Limit, Position Accountability, and Reportable Level Table 

(attached under separate cover)

(effective close of business March 30, 2021)

Appendix C

Analysis of Deliverable Supply – Silver Futures 

(attached under separate cover)