SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 24-044 (2 of 4)

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): January 16, 2024 Filing Description: Modifications to the Event 

Contracts 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

January 16, 2024

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 Event Contracts Market Maker Program

CBOT Submission No. 24-044 (2 of 4)

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME”), The Board of Trade of the City of Chicago, Inc. (“CBOT”), New York 

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

hereby notify the Commodity Futures Trading Commission (“CFTC” or “Commission”) of plans to modify the Event 

Contracts 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 underlined and deletions 

overstruck.

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

Commodity Exchange Act (“CEA”). During the review, Exchange 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 Exchanges’ ability to perform their trade practice and market surveillance obligations 

under the CEA. The Exchanges’ market regulation staff will monitor activity in the Program’s products to prevent 

manipulative trading and market abuse. Additionally, the Exchanges have implemented systems to track Program 

participants’ volume to ensure proper distribution of earned incentives. The Program does not affect the Exchanges’ 

order execution. Participants in the Program will be selected by Exchanges’ staff using criteria as set forth in Exhibit 1. 

Each of the Exchanges’ respective rules includes prohibitions against fraudulent, non-competitive, unfair or abusive 

practices. All participants must execute a contractual agreement with the Exchanges’ in which each participant 

expressly agrees to comply with, and be subject to, applicable regulations and applicable rules. The Program is subject 

to the Exchanges’ record retention policies which comply with the CEA. 

The Exchanges certify that the Program complies with the CEA and the regulations thereunder. There were no 

substantive opposing views to this Program.

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 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. 24-044 in any related correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

Event Contracts Market Maker Program

Program Purpose

The purpose of this Program is to incentivize market participants to support the launch and development of 

the products listed below. The resulting increase in liquidity benefits all participant segments of the market.

Product Scope

All Event Contracts that are traded on the CME Globex Platform (“Products”). 

Eligible Participants

The Exchanges may designate up to seven (7) participants in the Program. Participants may be members 

or non-members. Participants must be: (i) classified as a proprietary trading firm, and (ii) located in the 

United States, Singapore, or Hong Kong. 

Program Term

Start date is September 19, 2022. End date is January 31, 2024 July 31, 2024.

Hours

7:00AM – 3:00PM CT (“RTH”) and 5:00PM – 7:00AM CT (“ETH”).

Obligations

In order to be eligible to receive incentives, participants must quote two-sided markets in the Products at 

predetermined average bid/ask spreads and minimum quote sizes during a certain percentage of time-inmarket.

Incentives

Upon meeting all obligations, as determined by the Exchanges, participants will be eligible to receive 

predetermined incentives.

Monitoring and Termination of Status

The Exchanges shall monitor activity in the Products 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.