Market  Regulation Advisory Notices
To All Members, Clearing Members, Service Bureaus, and Independent Software Vendors
From Market Regulation
Subject Harmonized CME and CBOT Customer Type Indicator (CTI) Codes
Notice Date 2004-12-14
Notice Number RA-04-15
Effective Date  

REMINDER NOTICE

Harmonized CME and CBOT Customer Type Indicator (CTI) Codes

In accordance with the Core Principles of the Commodity Exchange Act, Exchange rules require a customer type indicator (“CTI”) code on every transaction executed electronically or by open outcry.  Recently, the Exchanges and the National Futures Association met and agreed on a harmonized set of CTI code definitions for the industry. 

In October 2004, CME and CBOT announced how the new CTI code definitions will be applied for CME and CBOT products.  Many Clearing Firms have already applied these new CTI definitions, while others are in the process of making system changes.  Both the CBOT and the CME are anticipating that all firms will apply the new CTI definitions no later than December 31, 2004.

CTI 1:  Electronic Trading and Open Outcry – Applies to transactions initiated and executed by an individual member for his own account, for an account he controls, or for an account in which he has an ownership or financial interest.  However, transactions initiated and executed by a member for the proprietary account of a member firm (as defined below) must be designated as CTI 2 transactions. 

New for CME:  CTI 1 includes trades executed by members who exercise control over another account except for proprietary accounts of member firms.  CTI 1 for electronic trading is reserved for members.

CTI 2:  Electronic Trading and Open Outcry – Applies to orders entered/trades executed for the proprietary accounts of a firm defined as follows:

            CME – clearing member firm, firms holding a membership pursuant to Rules 106.H., 106.I., 106.N., 106.R (also known as Electronic Corporate Members) or 106.S., and other similar member programs to be announced by CME.

            CBOT – category (1a), (1b), (2a), (2b), (2c), and (3) member firms as defined in Regulation 230.02, and their affiliates and designated passive investor entities as defined in Regulation 450.02(D), as well as category (4) e-cbot only member proprietary account of a clearing or non-clearing member firm will continue to participate in the CTI 2/1 Conversion Program.

New for CME and CBOT:    CTI 2 was previously reserved exclusively for the proprietary accounts of clearing member firms.

CTI 3:  Electronic Trading – Applies to orders entered by member or non-member terminal operator for the account of another individual member or an account controlled by such other individual member.

Open Outcry – Applies to orders that a member executes on behalf of another individual member, or for an account such other member controls or in which such other member has an ownership or financial interest.

New for CME and CBOT:    Open outcry orders entered for a member’s account through the normal customer order flow process will be coded as CTI 3 rather than CTI 4.

CTI 4:  Electronic Trading and Open Outcry – Applies to all orders/transactions not included in CTI categories 1, 2, or 3.  These typically are orders entered by or on behalf of non-member entities. 

New for CME and CBOT:    Member entities receiving preferential rates for their proprietary trading will be classified as CTI 2 rather than CTI 4.

Questions regarding this notice may be directed to any of the following individuals:

            CBOT:             Terry Quinn, Senior Manager, Office of Investigations & Audits

                                    tquinn@cbot.com or 312-435-3753

                                    Dean Payton, Vice President, Office of Investigations & Audits

                                    dpayton@cbot.com or 312-435-3658

            CME:               Jim Moran, Director, Market Regulation

                                    jmoran@cme.com or 312-930-8520

                                    Lou Abarcar, Manager, Market Regulation

                                    labarcar@cme.com or 312-648-3623       

                                    Rich Gustafson, Manager, Market Regulation

                                    rgustafson@cme.com or 312-930-8512