SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-439

Organization: Commodity Exchange, Inc. ("COMEX")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): October 17, 2023 Filing Description: Modifications to the 

Global Aluminum Asset Manager 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

October 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, DC 20581

RE: Modifications to the Global Aluminum Asset Manager Program

COMEX Submission No. 23-439

Dear Mr. Kirkpatrick:

Commodity Exchange, Inc. (“COMEX” or “Exchange”) hereby notifies the Commodity Futures Trading Commission 

(“CFTC” or “Commission”) of plans to modify the Global Aluminum Asset Manager Program (“Program”). The 

modifications to the Program will become effective on November 1, 2023.

Exhibit 1 sets forth the terms of the Program. Modifications appear below, with additions underlined and deletions 

overstruck.

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, 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 Exchange’s ability to perform its trade practice and market surveillance obligations 

under the CEA. The Exchange will monitor trading in the Program’s product to prevent manipulative trading and 

market abuse. Additionally, the Exchange has implemented systems to track Program participants’ volume to ensure 

proper distribution of earned incentives. The product included in this Program is listed for trading in the open and 

competitive market. Participants in the Program will be selected by Exchange staff using criteria as further stated in 

Exhibit 1. Chapter 4 of the Exchange rules includes prohibitions against fraudulent, non-competitive, unfair, or 

abusive practices. All participants must execute a contractual agreement with the Exchange in which each participant 

will expressly agree to comply with and be subject to applicable regulations and Exchange rules. The Program is

subject to the Exchange’s record retention policies which comply with the CEA.

COMEX certifies that the Program complies with the CEA and the regulations thereunder. There were no substantive 

opposing views to this Program.

The Exchange certifies that this submission has been concurrently posted on the Exchange’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 COMEX Submission No. 23-439 in any related 

correspondence.

Sincerely,

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel 

Attachment: Exhibit 1
EXHIBIT 1

Global Aluminum Asset Manager Program

Program Purpose

The purpose of this Program is to encourage market participants to increase volume in the product listed 

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

Product Scope

Aluminum futures (“ALI”) that are traded on the CME Globex Platform or cleared through CME ClearPort

(the “Product”).

Eligible Participants

There is no limit to the number of participants that may participate in the Program. Participants must be: 

(i) a non-member, and (ii) classified as an asset manager. Participants may not be enrolled in any other 

COMEX incentive program the Aluminum Market Development Program.

Hours

N/A

Program Term 

Start date is October 1, 2022. End date is October 31, 2023 January 31, 2025.

Obligations

Participants must meet certain volume thresholds, as determined by the Exchange, in order to receive the 

incentives.

Incentives

Upon meeting all requirements, as determined by the Exchange, participants will receive predetermined

incentives.

Monitoring and Termination of Status

The Exchange shall monitor trading activity and participants’ performance and shall retain the right to 

revoke participant status if it concludes from review that a participant has failed to meet the requirements 

of the Program.