SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-240

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): June 6, 2023 Filing Description: Implementation of the Eris 

Swap Futures Transfer Fee Waiver 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 

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

June 6, 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: Implementation of the Eris Swap Futures Transfer Fee Waiver Program

CBOT Submission No. 23-240

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 implement the Eris Swap Futures 

Transfer Fee Waiver Program. The proposed Program will become effective on June 23, 2023.

Exhibit 1 sets forth the terms of the Program.

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

the Commodity Exchange Act (“CEA” or “Act”). 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 is a general fee waiver that applies to all market participants. A general fee waiver does not 

incentivize manipulative trading or market abuse. The Program does not impact the Exchange’s ability to 

perform its trade practice and market surveillance obligations under the CEA. The Exchange’s market 

regulation staff will monitor trading in the products that are included in the Program to prevent 

manipulative trading and market abuse. The general fee waiver in the Program does not impact the 

Exchange’s order execution. All market participants that execute trades in the products shall be entitled to 

participate. Chapter 4 of the Exchange rules includes prohibitions against fraudulent, non-competitive, 

unfair, or abusive practices. The Program is subject to these rules and Exchange records retention

policies that comply with the CEA.

CBOT certifies that this submission has been concurrently posted on CBOT’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. 23-240 in any related 

correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1 
EXHIBIT 1

Eris Swap Futures Transfer Fee Waiver Program

Program Purpose

The purpose of this Program is to support the implementation of mandatory USD LIBOR fallbacks to

convert Eris LIBOR positions into Eris SOFR positions. 

Product Scope

All Eris LIBOR and SOFR Swap Futures (“Products”).

Eligible Participants

There is no limit to the number of participants in the Program. Participants may be members or nonmembers. The incentives described below will be automatically applied to all transactions in the Products

made by market participants.

Program Term 

Start date is June 23, 2023. End date is June 25, 2023 or the date upon which the mandatory conversion 

takes place. 

Hours

N/A

Incentives

Fee Waivers: All market participants will receive fee waivers on all transfer fees for the Products.