SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 24-043 (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 Latin 

America Fund Manager Incentive 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 Latin America Fund Manager Incentive Program

CBOT Submission No. 24-043 (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”) that they plan to modify the 

Latin America Fund Manager Incentive Program (“LAFMIP,” “FMIP,” or “Program”). The modifications to the Program

will become effective on February 1, 2024.

Exhibit 1 sets forth the terms of the Program. The modifications appear below, with additions underscored 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, the Exchanges’ 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 its trade practice and market surveillance obligations 

under the CEA. The Exchanges’ market regulation staff will monitor trading in the products in order to prevent 

manipulative trading and market abuse. The incentives in the Program do not impact the Exchanges’ order execution. 

Participants in the Program will be selected by the Exchanges’ staff using criteria as further stated in Exhibit 1. 

Chapter 4 of the Exchanges’ rules includes prohibitions against fraudulent, non-competitive, unfair or abusive 

practices. The Program is subject to these rules. The Program will be 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. 24-043 in any related 

correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

LATIN AMERICA FUND MANAGER INCENTIVE PROGRAM 

Program Purpose

The purpose of this Program is to incentivize Fund Managers in Latin American countries to trade the

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

segments in the market.

Product Scope

Certain CME, CBOT, NYMEX, and COMEX products available for trading on the Globex Platform, and all

CME Interest Rate Options traded via Open Outcry (“Products”).

Eligible Participants

There is no limit to the number of participants that may be selected in the Program. All approved CME, 

CBOT, NYMEX, and COMEX non-members may participate. Participation in the Program will be limited to 

a maximum continuous period of 24 months. After 24 months, participants will be removed from the 

Program. Participants registered in the Program as of February 1, 2024 will continue to be eligible for the 

Program through January 31, 2026. Additionally, participants must meet the following criteria. 

To qualify for LAFMIP, a Fund Manager must: 

• Be located and operating in a Latin American country. 

• Have assets under management of at least US $5 million. 

• Be registered and licensed by the government regulator in their respective country in Latin 

America and must submit to the Exchanges all related documentation of such registrations and 

licenses. 

• Have all traders physically located in Latin America. 

• Complete a LAFMIP application, pay an application fee, and be approved by the Exchanges. 

• Register Approved Funds with the Exchanges. Approved Fund accounts will receive discounted 

fees only on fund accounts that are solely managed by the LAFMIP participating Fund Manager. 

The LAFMIP participant must submit documentation showing they are the authorized manager 

of the fund account applying for discounted fees. 

• Trade the account of a hedge fund, certain specialized government-sponsored pension funds, 

commodity pool or other collective investment vehicle. Individual managed accounts and private 

pension funds do not qualify for the Program. 

• Execute all trades in the name of the Approved Fund account managed by the qualified LAFMIP 

firm. 

• Register all participating traders who must be owners, bona fide employees or independent 

contractors of the LAFMIP participant. 

Program Term

Start date is December 4, 2011. End date January 31, 2024 January 31, 2026.

Hours

The incentives will apply to all trades made in the Products regardless of the execution time.
Obligations

Participants must maintain a minimum average daily volume (“ADV”) of 100 sides, measured on a 

quarterly basis. All Micro contracts will be excluded from this ADV requirement.

Incentives

Fee Discounts: Upon meeting all obligations, as determined by the Exchanges, participants will be eligible 

to receive discounted fees for the Products in accordance with the following:

GLOBEX

Product Category

(For executed trades on Globex only)

FMIP Fees

(per side)

CME Products

E-mini Equity Index Futures – Outrights 

(excluding Dividend Index Futures)

$1.11 $1.16

E-mini Equity Index – Options $0.51

Case Schiller Housing Index Futures –

Outrights $1.16

Micro E-Mini Equity Index Futures – Outrights $0.24

Micro E-Mini Equity Index Futures – Spreads $0.24

Micro E-mini Equity Index Options – Outrights $0.15

Micro E-mini Equity Index Options – Spreads $0.12

Bitcoin Futures – Outrights, Spreads $5.60 $6.10

Bitcoin Options $4.87

Interest Rate Futures – Front Months $0.83

Interest Rate Futures – Back Months $0.78

Interest Rate Options $0.64

Foreign Exchange – Full Size Futures 

(excluding FX Link) $1.09
Foreign Exchange – Full Size Options $1.09

CBOT Products

E-mini Dow/DJ U.S. Real Estate $1.11 $1.16

Micro E-Mini Dow $0.24

Micro Treasury Yield Futures $0.28

2-Year & 3-Year U.S. Treasury Futures $0.62

5-Year U.S. Treasury Futures $0.62

10-Year & Ultra 10-Year U.S. Treasury Futures $0.72

All other U.S. Treasury Bond Futures $0.79

Ultra U.S. Treasury Bond Futures $0.82

TBA Futures $0.57

U.S. Treasury Options $0.58

Fed Fund Contracts $0.65

Full Size Agricultural Contracts* $1.78

NYMEX Products

Energy Contracts (Physicals) on CME Globex

(CL, LO, HO, OH, RB, OB, NG, LN, ON)*

$1.27

Henry Hub Natural Gas Look-Alike Options 

(LN) $1.27

Henry Hub Natural Gas Futures (NG)* $1.27 

Henry Hub Natural Gas Options (ON) $1.27 

Light Sweet Crude Oil (WTI) Futures (CL)* $1.27 

Light Sweet Crude Oil Options (LO) $1.27 

NY Harbor ULSD Futures (HO)* $1.27 

RBOB Gasoline Futures (RB)* $1.27 

NYMEX Metals (PL, PA)* $1.27

COMEX Products
Metals Futures Contracts (Physicals) on CME 

Globex Core Metals (GC, SI, HG)*

$1.27

Gold (Enhanced Delivery) Futures $1.27

*For the products denoted with an asterisk above, Globex TAS transactions will be excluded from the 

Program.

OPEN OUTCRY

Product Category

(For executed trades via Open Outcry only)

FMIP Fees

(per side)

CME Products

Interest Rate Options $0.62

Monitoring and Termination of Status

The Exchanges 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 requirements of 

the Program.