SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested

Registered Entity Identifier Code (optional): 23-392

Organization: Chicago Mercantile Exchange Inc. ("CME")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): September 8, 2023 Filing Description: Modifications to the 

TOPIX Futures Market Maker 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

September 8, 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 TOPIX Futures Market Maker Program

CME Submission No. 23-392

Dear Mr. Kirkpatrick:

Chicago Mercantile Exchange Inc. (“CME” or “Exchange”) hereby notifies the Commodity Futures Trading 

Commission (“CFTC” or “Commission”) of plans to modify the TOPIX Futures Market Maker Program (“Program”). 

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

Exhibit 1 sets forth the terms of this 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 and the Exchange’s market regulation staff will monitor trading in the Program’s products to prevent 

manipulative trading and market abuse. Additionally, the Exchange has implemented systems to track Program 

participants’ obligations to ensure proper distribution of earned incentives. The incentives in the Program do not 

impact the Exchange’s order execution. 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, noncompetitive, 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 the 

Exchanges rules. The Program is subject to the Exchange’s record retention policies which comply with the CEA. 

The Exchange 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 CME Group 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 CME Submission No. 23-392 in any related correspondence.

Sincerely,

/s/ Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachment: Exhibit 1
EXHIBIT 1

TOPIX Futures Market Maker Program

Program Purpose 

The purpose of this Program is to support the development of the products listed below on the CME 

Globex Platform (“Globex”). The resulting increase in central limit order book liquidity benefits all 

participant segments in the market.

Product Scope

Yen Denominated TOPIX Index Futures (“TPY”) and USD Denominated TOPIX Index Futures (“TPD”)

that are traded on Globex (“Products”).

Eligible Participants

The Exchange may designate up to seven (7) participants in the Program. Participants may be members

or non-members. Prospective participants are required to submit an application/bid sheet to the 

Exchange as part of a competitive application process which is used to determine eligibility. In 

determining whether a prospective participant is selected to participate in the Program, Exchange staff 

may take into account a variety of factors including the strength of the quoting obligations the prospective 

participant is willing to commit to provide, whether Exchange staff believes that the prospective participant 

can maintain such obligations, and historical volume trading similar contracts. The Exchange may, from 

time to time, add or subtract from the aforementioned requirements as it deems necessary.

Program Term 

Start date is February 5, 2018. End date is September 30, 2023 September 30, 2024.

Obligations

In order to be eligible to receive the incentives, participants must quote two-sided markets in the Products

at predetermined average bid/ask spreads.

Incentives 

Upon meeting all obligations, as determined by the Exchange, participants may be eligible to 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 no longer meets the eligibility 

requirements or fails to meet the obligations of the Program.