SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-531

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 

Electronic Treasury Options 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 Electronic Treasury Options Market Maker Program

CBOT Submission No. 23-531

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 plans to modify the Electronic Treasury Options 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 all 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, noncompetitive, 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 or the proposed extension.

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. 23-531 in any related 

correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

Electronic Treasury Options Market Maker Program

Program Purpose

The purpose of this Program is to enhance liquidity in Treasury Options products during RTH and ETH in 

order to increase the percentage of Treasury Options executed electronically. A more liquid contract 

benefits all participants in the market.

Product Scope

All Options on CBOT Treasury futures, including 2, 5, and 10-Year U.S. Treasury Notes, 30-Year U.S. 

Treasury Bonds, Long Term U.S. Treasury Bonds, and Ultra 10-Year Notes (“Products”).

Eligible Participants

There is no limit to the number of participants that may participate in the Program. Participants may be 

CBOT members or non-members. 

Program Term

Start date is March 2008. End date is January 31, 2024 January 31, 2025.

Hours

Extended and Regular Trading Hours (“ETH” and “RTH”).

Obligations

Quoting Requirements: Participants are required to respond to Globex electronic Requests-for-Quotes 

(“RFQs”) in strategies of all or a subset of the Products. Participants may only quote up to the max order 

quantity on a single price level and must set market maker protection values in line with quoted quantities.

Additionally, participants must quote in accordance with the mass quote obligations and other associated 

market maker functionality parameters as determined by the Exchange and as published on the

Exchange’s website.

Incentives

Mass Quote Message: CBOT shall permit the market maker to submit quotes for the Product using the 

Mass Quote message under an assigned identification granted by CBOT staff.

Order Flow Allocation: The eight (8) most highly ranked participants in each Treasury option product shall 

receive order flow allocations in the applicable Treasury option product, per the schedule of “Evaluation 

and Incentive Allocation Periods.” In order to receive the allocation, the top eight (8) participants must 

respond to at least 60% of RFQs in a specific product or at least 50% of their Treasury options volume 
must be executed on Globex. The total order flow allocations shall not exceed 24% of total order flow in 

the applicable Treasury option product.

The Exchange shall evaluate and rank participants quarterly with assignments of attendant rank-related 

Program incentives to take effect per the following schedule:

Evaluation and Incentive Allocation Periods for 2, 5, and 10-Year U.S. Treasury Notes, 30 

Year U.S. Treasury Bonds, Long Term U.S. Treasury Bonds, and Ultra 10-Year Notes

Evaluation Period Incentive Allocation Period

9/16/2022 2023 – 12/15/2022 2023 1/1/2023 2024 – 3/31/2023 2024

12/16/2022 2023 – 3/15/2023 2024 4/1/2023 2024 – 6/30/2023 2024

3/16/2023 2024 – 6/15/2023 2024 7/1/2023 2024 – 9/30/2023 2024

6/16/2023 2024 – 9/15/2023 2024 10/1/2023 2024 – 12/31/2023 2024

9/16/2023 2024 – 12/15/2023 2024 1/1/2024 2025 – 3/31/2024 2025

Participants shall be ranked on the basis of the speed of their responses, the width of their bid-offered 

price spreads, the sizes of their bids and offers, time persistence of their quoting in options, and their 

electronic volume within the weeklies, serial, and quarterly expiration months.

Monitoring and Termination of Status

The Exchange shall monitor trading activity and participants’ performance and shall retain the right to 

revoke participant status if it concludes from review that a participant no longer meets the eligibility 

requirements or fails to meet the obligations of the Program.