SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 23-332

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

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 08/10/23 Filing Description: Increase of Spot Month Position 

Limit for Aluminum Futures and Option 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

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

August 10, 2023

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 Limit of the

Aluminum Futures and Option Contracts.

COMEX Submission No. 23-332

Dear Mr. Kirkpatrick:

Commodity Exchange, Inc. (“COMEX” or “Exchange”) is certifying to the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) an increase of the spot month position limit of the Aluminum Futures 

and Aluminum Option contracts as noted below (the “Contracts”) effective on August 25, 2023, and

commencing with the October 2023 contract month and beyond.

(additions underscored; deletions struck through)

Contract Title Rule 

Chapter

Commodity 

Code

Reporting 

Level

Spot-Month 

Limit

(In Net 

Futures 

Equivalents)

Single Month 

Accountability 

Level

(In Net Futures 

Equivalents)

All Month 

Accountability 

Level

(In Net Futures 

Equivalents)

Aluminum 

Futures 107 ALI 10 150 200 500 500

Aluminum 

Option 123 AX 10 150 200 500 500

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 the amended spot month position limits of the Contracts. Exhibit A reflects the 

amendments to the Table as of August 25, 2023, the effective date of this submission, and Exhibit B reflects 

the amendments to the Table effective on the close of business on September 28, 2023, the date that 

October 2023 becomes the lead contract month (collectively, the “Rule Amendments”). Exhibits A and B 

are provided in blackline format under separate cover.

Consistent with Core Principle 3 of the Commodity Exchange Act, Appendix C of Part 38, the Exchange 

based the definition of deliverable supply on existing registered and eligible inventories at its Exchange 

approved warehouses for Exchange delivery. 

As of July 31, 2023, the aluminum inventory held at Exchange approved warehouses totaled 19,431 metric 

tons, the equivalent of 777 Aluminum futures contracts (contract size = 25 metric tons). Exchange practice 

is to set spot month position limits at a maximum level of 25% of deliverable supply over the most recent 

three-year period. Deliverable supply is calculated as the sum of total reported registered aluminum with 
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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total reported eligible aluminum. Table 1. below shows the monthly average aluminum stocks in Exchange 

approved warehouses for the most recent three-year period in contract equivalents. 

Inventory and Capacity of Exchange Approved Warehouses

Over the most recent three-year period, the monthly average registered aluminum was 637 futures 

equivalent contracts. The monthly average eligible aluminum was 584 futures equivalent contracts. Based 

on the foregoing, the Exchange estimates monthly deliverable supply for the Aluminum Futures (ALI) 

contract at approximately 1,221 futures equivalent contracts.

 

Table 1. Monthly Average Stock Levels at Exchange Approved Warehouses for Aluminum (in 

Contract Equivalents)

Month

Average of 

Registered 

(Contract 

Equivalent)

Average of 

Eligible 

(Contract 

Equivalent)

Average 

Inventory 

Total 

(Contract 

Equivalents)

Aug-20 903 870 1,773

Sep-20 917 972 1,889

Oct-20 1,103 871 1,974

Nov-20 1,355 489 1,844

Dec-20 1,362 496 1,858

Jan-21 1,334 488 1,822

Feb-21 1,339 437 1,777

Mar-21 1,068 482 1,549

Apr-21 938 318 1,256

May-21 910 330 1,240

Jun-21 784 414 1,198

Jul-21 847 522 1,369

Aug-21 1,064 563 1,628

Sep-21 783 786 1,568

Oct-21 643 917 1,560

Nov-21 459 935 1,394

Dec-21 322 903 1,224

Jan-22 308 855 1,163

Feb-22 239 788 1,026

Mar-22 245 705 950

Apr-22 488 615 1,103

May-22 456 548 1,004

Jun-22 401 505 906

Jul-22 382 555 937

Aug-22 382 568 950

Sep-22 382 469 851
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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Oct-22 382 401 784

Nov-22 382 368 750

Dec-22 418 343 762

Jan-23 411 306 716

Feb-23 299 387 686

Mar-23 351 588 939

Apr-23 174 904 1,078

May-23 343 521 864

Jun-23 268 499 768

Jul-23 488 293 781

3-year 

average 637 584 1,221

Source: CME Group

The proposed spot month position limit of 200 contracts represents 16.38% of the estimated monthly 

deliverable supply for the most recent three-year period. The proposed spot month position limit for the 

Aluminum Option contract would aggregate into Aluminum Futures for position limit purposes. The 

Exchange will continue to closely monitor the Contracts’ deliverable supply. 

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

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

the following Core Principle: 

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. 

Availability of General Information: The Exchange will make publicly available the details of the 

spot month position limit decreases by publishing a Market Surveillance Notice (“MSN”) to the 

market. The MSN will also be available on CME Group’s website. 

The Exchange certifies that the Rule Amendments comply with the Act and regulations thereunder. There 

were no opposing views to the Rule Amendments.

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.
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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Should you have any questions concerning the above, please contact the undersigned at 212-299-2200 or 

via e-mail at CMEGSubmissionInquiry@cmegroup.com. 

 Sincerely,

 /s/ Christopher Bowen 

 Managing Director and Chief Regulatory Counsel

Attachments: Exhibit A – Amendments to COMEX Rulebook Chapter 5 Position Limit, Position 

Accountability, and Reportable Level Table (effective August 25, 2023) (under 

separate cover) 

Exhibit B – Amendments to COMEX Rulebook Chapter 5 Position Limit, Position

Accountability, and Reportable Level Table (effective close of business September 28, 

2023) (under separate cover)

 

 
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Exhibit A

 

 COMEX Rulebook 

 Chapter 5 

(“Trading Qualifications and Practices”) 

Position Limit, Position Accountability, and Reportable Level Table 

 (under separate cover) 

 (Effective close of business August 25, 2023) 

 Exhibit B

 

 COMEX Rulebook 

 Chapter 5 

(“Trading Qualifications and Practices”) 

Position Limit, Position Accountability, and Reportable Level Table 

 (under separate cover) 

 (Effective close of business September 28, 2023)