Daily Submission of Large Trader Data

This Advisory Notice supersedes CME & CBOT Market Regulation Advisory Notice RA0801-3 from February 14, 2008, and is being issued to summarize Large Trader reporting requirements for CME, CBOT, NYMEX, COMEX and the Dubai Mercantile Exchange (“DME”).  Rule 561 (“Reports of Large Positions”) require exchange clearing members, omnibus accounts and foreign brokers to submit a daily report of all positions required to be reported as set forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations Section at the end of Chapter 5 of the CME, CBOT, NYMEX and COMEX Rulebooks.  Rule 561 is presented in its entirety on page 2 of this Advisory Notice. 

Important information concerning the May 3, 2010, deadline for firms to be in compliance with the requirement that their daily Large Trader position file include both Delivery Notices and Exchange for Related Positions (“EFRP”) records also appears on page 2.

Daily Deadlines

The deadline for daily FTP submission of the Large Trader position file is 7:00 a.m. Central Time (“CT”), (8:00 a.m. Eastern Time (“ET”) for CBOT, CME, NYMEX and COMEX products, and 11:00 p.m. CT (12:00 a.m. ET) for DME products.  Error corrections or any other adjustments to the Large Trader position file must be completed by 8:00 a.m. CT (9:00 a.m. ET), and these adjustments must be made using the web-based Large Trader Reportable Position (“LTRP”) application, accessed at http://connect.cme.com.

Member firms can request user IDs and passwords for access to the LTRP application by completing and submitting a Member Firm On-Line System Access Request Form available at http://cmegroup.com/clearing/files/onlineaccess.pdf.  Questions concerning user ids and passwords should be directed to the Customer Support Group at 312.930.3444.

Omnibus Account Reporting

Omnibus accounts must submit large trader reportable positions directly via FTP to the CME Group File Server.  Omnibus reporting entities can submit large trader positions using the CFTC-assigned alpha firm ID.   If an omnibus entity does not currently submit large trader positions and is not set up to submit via FTP, the entity should contact the Market Regulation Department to obtain an alpha firm identification ID.  The omnibus entity can use the following large trader file layout:  http://www.cftc.gov/industryoversight/marketsurveillance/ltrformat.html.

Updated LTRP User Guide

The revised version of the LTRP User Guide which documents enhancements to the LTRP application is accessible via the Client Management Training Services page of the CME Group Web site at http://www.cmegroup.com/clearing/systems-operations/user-guides.html or http://www.cmegroup.com/clearing/files/large-trader-report.pdf.  Questions concerning the use of the system should be directed to Client Management Training Services at 312.930.4523.  

Delivery Notices and Exchange for Related Positions Records

Pursuant to Rule 561.A., a firm’s daily Large Trader position file is required to include both Delivery Notices and EFRP records, in addition to the reportable position records.  Please refer to following large trader file layout for specifications for reporting of delivery notices and EFRPs:  http://www.cftc.gov/industryoversight/marketsurveillance/ltrformat.html.  Please note that the CFTC large trader file layout identifies Delivery Notices and EFRPs by the acronyms “DN” and “EP.”

Firms not yet reporting Delivery Notice and EFRP records may submit files for testing and confirmation purposes by calling the Customer Support Group at 312.930.3444.  For those firms already submitting Delivery Notice and EFRP records, no further changes are necessary.  All firms must be in compliance with this requirement and be accurately submitting Delivery Notice and EFRP records no later than Monday, May 3, 2010.

If you have any questions, please contact Sandra Valtierra, Manager, Market Surveillance, at 312.347.4137 or Danyelle Franks, Senior Database Integrity Administrator, Market Surveillance, at 312.341.7646

For media inquiries concerning this Advisory Notice, please contact CME Group Corporate Communications at 312.930.3434 or news@cmegroup.com.

Rule 561.          Reports of Large Positions

561.A.    General Provisions

Clearing members, omnibus accounts and foreign brokers shall submit to the Exchange a daily report of all positions required to be reported as set forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations Section at the end of Chapter 5.  Positions at or above the reportable level in a particular expiration month of a futures contract or in all puts or in all calls of a particular option contract expiration month trigger reportable status.  For a person in reportable status in a particular contract, all positions, regardless of size, in any futures contract month and in any put or call on that futures contract must be reported.

Additionally, the daily Large Trader submission to the Exchange must include for each reportable account 1) the EFRP volume bought and sold in the reportable instrument, by contract month, and for EOOs by put and call strike and 2) the number of delivery notices issued and the number of deliveries stopped in the reportable instrument.

Failure by an omnibus account or foreign broker to submit required information may result in a hearing by the Business Conduct Committee and result in limitations, conditions or denial of access of such omnibus account or foreign broker to any Exchange market.  Notwithstanding the above, clearing members carrying such accounts remain responsible for obtaining and providing to the Exchange information regarding the ownership and control of positions in circumstances where an omnibus account or foreign broker has failed to provide the information to the Exchange.

All large trader reports shall be submitted in a form acceptable to the Market Regulation Department.  The Exchange may require that more than one large trader report be submitted daily.  The Business Conduct Committee or the Market Regulation Department may require reports from any clearing member, omnibus account or foreign broker on a lesser number of positions than reflected in the Position Limit, Position Accountability and Reportable Level Table.

Clearing members, omnibus accounts and foreign brokers must provide the Market Regulation Department with the required CFTC Form 102 (“Identification of Special Accounts”) identifying the owner, any controlling parties and any additional required information for each reportable account.  The form must be submitted to the Market Regulation Department no later than the business day following the date on which the account becomes reportable.  Additionally, any material changes to the information previously provided to the Market Regulation Department will require the submission of a revised form within three business days of such changes becoming effective.

561.B.    Reportable Levels

The reportable levels for all contracts are set forth in the Position Limit and Reportable Level Table in the Interpretations Section at the end of Chapter 5.