SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-290 (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): July 17, 2023 Filing Description: Modifications to the 

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

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

July 17, 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 International Incentive Program

CBOT Submission No. 23-290 (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

International Incentive Program (“Program” or “IIP”). The modifications to the Program will become effective on 

August 1, 2023.

Exhibit 1 sets forth the terms of the 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, 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 incentivize manipulative trading or market abuse and 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 trading in the products under the Program 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 is subject to the Exchanges’ record retention policies which comply with the CEA.

CME, CBOT, NYMEX, and COMEX 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. 23-290 in any related 

correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

INTERNATIONAL INCENTIVE PROGRAM 

Program Purpose 

The purpose of this Program is to incentivize proprietary trading firms located outside North America 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 CME Globex® Platform,

and all open outcry transactions for CME Interest Rate options (“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. Only proprietary trading firms located outside 

of North America and traders located outside of North America are eligible.

To qualify as a proprietary trading firm under IIP a firm must:

Be a legal entity that trades its own capital. Trading funds must be exclusively firm funds and all trading 

must be done in the firm’s accounts. Further, to qualify for IIP, a proprietary trading firm must meet the 

following criteria: 

• All trading must be done in proprietary trading accounts held in the name of the firm. 

• All trading must be done electronically by owners, employees or contractors of the firm. 

• Only the firm’s capital can be at risk of loss; that is, no traders may make any trading capital 

contributions or payments to the firm nor have any capital at risk in connection with their trading of the 

firm’s proprietary accounts. 

• All trading must be solely for the benefit of the firm. No other individuals or entities can have any 

ownership interest in these accounts. 

• All funds contributed to and traded under the firm are subject to loss from any and all trading activity 

of the firm. 

• All profits and losses of the account are booked to income of the firm. 

• Net profits of the account after the distribution of trader incentives and deduction of expenses are 

taxed to the firm. 

Program Term 

Start date is December 16, 2011. End date is July 31, 2023 January 31, 2024.

Hours

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

For continued eligibility, IIP participants must maintain a combined average daily volume (“ADV”) in the 

Products of 250 contracts (sides) measured over a given calendar quarter. Micro E-mini Equity Index 

products will be excluded from this ADV requirement.

Incentives

Upon meeting all obligations, as determined by the Exchanges, participants will receive the following 

incentives:

1. Fee Discounts: Participants will be eligible to receive fee discounts for the Products in accordance with 

the following tables:

Product Category

CME Globex® Only

IIP All-in Fees

(Per Side)

CME Products

Agricultural – Futures1 $0.89

Agricultural – Options1 $0.89

Lumber Futures $0.82

Weather Contracts $0.26

Full Size Foreign Exchange – Futures*

(excluding FX Link) $0.54

Full Size Foreign Exchange – Futures via FX 

Link $0.60

Foreign Exchange – Options* $0.54

E-mini Foreign Exchange Contracts* $0.54

E-micro Foreign Exchange Contracts $0.15

Full Size Equity Index – Futures $1.10

E-mini Equity Index – Futures* (Outrights & 

Spreads) $0.70

E-mini Equity Index – Options* $0.50

Micro E-Mini Equity Index – Futures $0.18

Micro E-mini Equity Index – Options (Outrights 

& Spreads)

$0.10

Nikkei/TOPIX Futures (Outrights & Spreads) $1.10

Interest Rate Futures* $0.50

Interest Rate Options* $0.50

CBOT Products

Full Size Agricultural Contracts1 $1.11

Mini Agricultural Contracts $0.90

ICS & CS Agricultural Options $2.06

E-mini Dow/DJ U.S. Real Estate $0.70

Micro E-Mini Dow Futures $0.18

Eris Swap Futures $0.50

Micro Treasury Yield Futures $0.21

TBA Futures $0.50

U.S. Treasury Futures $0.54

U.S. Treasury Options $0.54

Fed Fund Products $0.49

MAC Swap Futures $0.49
Product Category

NYMEX Products on CME Globex®

IIP All-in Fees

(Per Side)

Core Energy (CL, LO, HO, OH, RB, OB, NG, 

LN, ON)1 $0.90

NYMEX Metals (PL, PA)1 $1.00

All other Energy

Must be 10% 

greater than the 

highest member rate

COMEX Products on CME Globex® -

Futures Only 

Core Metal (GC, SI, HG)1 $1.00

E-micro Gold (MGC) $0.20

1,000 oz. Silver (SIL) $0.40

Shanghai Gold (SGC, SGU) $1.00

Gold (Enhanced Delivery) Futures (4GC) $1.00

Product Category

Pit Trading

IIP All-in Fees

(Per Side)

CME Products

Interest Rate Options* $0.50

1For the products denoted with a 1 above, Globex TAS transactions will be excluded from the Program

upon implementation by the Exchanges.

*The products denoted with an asterisk above will be eligible for the additional CME Products Progressive 

Volume Discount Incentives listed in #2 below.

2. CME Products Progressive Volume Discount Incentives: Subject to the restrictions set forth in #3 

below, participants in the Program that maintain an ADV of 1,000 5,000 combined contract sides traded in 

the respective CME Products denoted above are eligible to receive progressive volume fee discounts in 

those Products as set forth below. 

CME Products for IIP – Fee Discounts

Tier Structure Interest Rates FX e-Mini Equity 

Futures

e-Mini Equity 

Options

0 – 1000 5,000 No Discount No Discount No Discount No Discount

1001 - 5000 $0.15 $0.13 $0.20 $0.10

5,001+ $0.25 $0.18 $0.25 $0.13

3. Restrictions: Participants may choose to participate in the Program on a Product Group by Product 

Group basis but must select which Product Groups they want to include under the Program when 

submitting their initial application. Participants may not receive incentives under the IVIP for volumes in 

Products counted toward this Program. 
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 eligibility 

requirements or fails to meet the obligations of the Program.

If a participant does not meet the minimum volume requirements during one (1) calendar quarter of the 

Program, the participant will still be eligible to receive the incentives for that applicable quarter. In order to 

continue to receive the incentives, participants must meet the minimum volume requirements for all 

subsequent calendar quarters.