SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-510 (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): December 12, 2023 Filing Description: Modifications to the 

APAC FCM 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

December 12, 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 APAC FCM Incentive Program

CBOT Submission No. 23-510 (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 APAC 

FCM Incentive Program (“Program”). The modifications to the Program will become effective on January 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. 23-510 in any related correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

APAC FCM Incentive Program

Program Purpose

The purpose of the Program is to incentivize participants to educate their customers about the benefits of 

trading the Exchanges’ products and centralized clearing, ultimately providing additional liquidity to the 

marketplace. A more liquid contract benefits all participants in the market.

Product Scope

All CME, CBOT, NYMEX, and COMEX products that are traded on the Globex Platform, excluding 

cryptocurrency and event contracts (“Products”).

Eligible Participants

There is no limit to the number of firms that can participate in the Program. The Exchange may designate 

up to thirty-five (35) participants in the Program. All approved CME, CBOT, NYMEX, and COMEX FCMs 

with non-member retail volume in the APAC region may participate. Participants must complete the APAC 

FCM Incentive Program application to be eligible for the Program.

Program Term

Start date is October 6, 2016. End date is December 31, 2023 December 31, 2024.

Hours

N/A

Obligations

Once accepted into the Program, participants must participate in at least two (2) marketing-planning 

sessions with the Exchanges on an annual basis and perform marketing initiatives which highlight CME, 

CBOT, NYMEX, and/or COMEX Products, excluding cryptocurrency contracts.

Incentives

Upon meeting all eligibility requirements and obligations, as determined by the Exchanges, participants 

may 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 obligations of the Program.