IPMI submits letter to the CME expressing concern over Modifications to NYMEX/COMEX Fee Schedule for Precious Metals Futures

5101 N 12thAve Suite C Pensacola FL 32504 mail@ipmi.org
www.ipmi.org

maureen.guilfoile@cmegroup.com
Maureen Guilfoile
Managing Director and Chief Regulatory Counsel
CME Group
20 S Wacker Dr
Chicago, IL 60606
Re: Modifications to NYMEX/COMEX Fee Schedule for Precious Metals Futures
NYMEX Submission No. 25-252

Dear Ms. Guilfoile,

On behalf of the International Precious Metals Institute and its membership, we write to express our profound concerns over
the recent modifications to the NYMEX/COMEX fee schedule for precious metals futures, effective July 14, 2025. The 900%
jump in the delivery notice fee – from $1 to $10 per contract – imposes an unjust and exclusive burden on the precious metals
market, which is the only contract market singled out by this increase. The automated electronic process for issuing a delivery
notice for gold, silver, platinum, or palladium is identical to that for copper, yet the copper contract continues to incur only a $1
fee. Assessing a vastly higher charge for the same automated service is akin to charging $10 for issuing a stock certificate for
General Motors; meanwhile, all other certificates of public companies incur a $1 fee, without a scintilla of difference in
process, effort, or expense. Imposing such a significant cost in relation to an automated process, in an industry that is already
stretched by razor-thin margins, is likely to destabilize established business models and diminish market liquidity.

Furthermore, the abrupt implementation of these changes left industry members with no opportunity for dialogue. Many firms
only learned of the revised fee schedule after publication, limiting their ability to adapt their business processes. We urge CME
Group to engage impacted stakeholders in advance and ensure far greater transparency before instituting changes of such
magnitude.

We respectfully request reconsideration of the fee increase from $1 to $10 per contract. We also urge CME Group to engage
directly with market participants in advance of any future changes, to ensure the transparency and predictability upon which
these markets rely. Our membership is ready to work with the exchange to develop a solution that supports the exchange’s
operational needs and the long-term health of the precious metals market.

Thank you.

Sincerely,

Larry Drummond, Executive Director
International Precious Metals Institute

cc: Thomas Hart (thomas.hart@cmegroup.com)
James Sullivan (sullivan@cmegroup.com)