To clarify the report requirements and transitional arrangements for program trading at the Zhengzhou Commodity Exchange (“ZCE”), strengthen the oversight of program trading, regulate program trading activities, and maintain an orderly and fair futures market, the following announcement is hereby given in accordance with the Program Trading Rules of Zhengzhou Commodity Exchange (“Program Trading Rules”).
I. Program Trading Report
(I) Who Needs to Submit a Report
A trader at the ZCE who meets one or more of the following criteria is required to submit a report:
1. Placing and canceling 10 or more orders within 1 second on 10 or more occasions in a single trading day. For the purpose of this rule, accounts linked by actual control relationship are treated as a single client account;
2. Letting a computer to automatically determine all the critical elements of a trading order such as contract code, buy/sell direction, order size, and order price as well as the timing of such order;
3. Using a self-developed or customized program trading software; or
4. Any other circumstance need to report recognized by the ZCE.
(II) What Information to Report
1. Basic account information, including the trader’s name, trading code, product manager, the carrying Futures brokerage Member (“FB Member”) or overseas broker,etc.;
2. Trading and software information, including the method of trading order execution, the name, basic functions, and developer of the trading software, etc.; and
3. Any other information required by the ZCE.
A program trader shall submit the change report within thirty(30) trading days after any significant change to the previously reported information.
A program trader shall ensure the reported information is true, accurate, and complete. The FB Member or overseas broker shall verify the reported information. Upon verification with no discrepancies, the FB Member shall report to the ZCE within five (5) trading days, and the overseas broker shall report to the ZCE through its carrying FB Member within five (5) trading days. Additionally, an FB Member or overseas broker shall verify the information reported by its program trading clients semiannually or as required by the ZCE. Where a client fails to report information as required, the FB Member or overseas broker shall urge the client to make corrections. Where the client fails to make corrections after being urged, the FB Member or overseas broker shall, in accordance with the Program Trading Entrustment Agreement, refuse to accept any further orders to open positions from the client.
(III) How to Submit a Report
A program trading client shall submit the report in accordance with the requirements of the Program Trading Rules. The FB Member and overseas broker shall report the clients’ program trading information to the ZCE through CFMMC’s program trading report system in accordance with the Notice on the Launch of China Futures Market Monitoring Center’s Program Trading Report System.
A non-FB Member shall report relevant information to the ZCE through the ZCE’s member service system before engaging in program trading.
Reporting requirements for high-frequency traders will be announced by the ZCE separately.
II. Transitional Arrangements
The following arrangements apply to FB Members, overseas brokers, and traders that have been engaged in program trading activities before October 9, 2025.
1. Before April 8, 2026, a FB Member shall enter into a Program Trading Entrustment Agreement with the client to stipulate the rights and obligations of both parties and clarify the requirements for reporting, risk management, and other matters. An overseas broker accepting a client’s entrustment for program trading shall be subject to the requirements of the preceding requirements.
2. A trader shall report program trading information through the designated channels truthfully, accurately, and completely . Starting from April 9, 2026, traders who fail to report program trading through the designated channels will not be allowed to engage in program trading.
3. For high-frequency traders and clients frequently involved in abnormal behaviors such as erroneous orders, the ZCE may require its carrying FB Member to test the technical system they use for program trading. Such system shall be tested by the FB Member either directly or through a third-party testing organization.
III. Supervisory Requirements
Any program trader that violates applicable rules may be ordered to make corrections and be subject to such measures taken by the ZCE as an alert, requiring a written explanation, arranging for a regulatory meeting, and restricting the opening of new positions.Any FB Member or overseas broker that violates applicable rules may be ordered to make corrections and be subject to such measures taken by the ZCE as an alert, arranging for a regulatory meeting, issuing a written warning, and issuing a supervisory opinion letter.Any serious violation will be handled in accordance with the Rules of Zhengzhou Commodity Exchange on Violations.
Instructions for the Reporting Form
for
Futures Market Program Trading
Clients
1. Client
Name: For an individual client, this should match the name appearing on the
ID card. For a general institutional client or special institutional client,
this should match the name appearing on the Organization Code Certificate. A
special institutional client should additionally fill in the name of the
relevant investment vehicle that is managed through a segregated account. For
overseas clients, this information should match the information kept in China
Futures Market Monitoring Center’s (CFMMC) Unified Account Opening System.
2. Client
Type: The three types are “Individual,” “General Institutional Client,” and
“Special Institutional Client” (choose one only). For an overseas client, this
information should match the information kept in CFMMC’s Unified Account
Opening System. Client type cannot be altered later.
3. Submitter Contact Person:
Usually this is the person who submits the program trading report on the submitter’s
behalf.
4. Contact Tel.: The
contact person’s landline or cellphone number. If more than one number is
provided, separate them with a (half-width) comma (“,”).
5. Client's Business Manager:
For an individual client, fill in the name of the client; for an institutional
client such as a private fund, trust, QFII, or RQFII, fill in the name of the
person overseeing the client’s program trading activities.
6. Manager Tel.: The phone
number for contacting the client’s program trading manager. If more than one
number is provided, separate them with a (half-width) comma (“,”).
7. Product Manager: Fill
in the name and contact details of the manager of the relevant investment
product (vehicle). This information is mandatory for special institutional
clients. Individuals, general institutional clients, and those without a
product manager, should write “N/A.”
8. Submitter Verification:
This section contains three items to be checked by the submitter. Fill in “Yes”
or “No” next to each item.
¨ We have verified the information
reported by the client for truthfulness and completeness, and undertake to
fulfill our management obligations in relation to the program trading client.
¨ We have understood the rules of the
exchange on program trading report, and educated our clients and informed them
about the related risks, to ensure effective risk management, and supervise
clients to trade in a rational and compliant manner.
¨The client understands the rules of
the exchange on program trading report, and undertakes the report is truthful,
accurate and complete. The client is aware of the supervisory requirements on
program trading, and will trade in a rational and compliant manner and bear all
consequences of the related activities.
This form may be submitted
only if all three items are marked “Yes.”
9. Exchange:
Select “Zhengzhou Commodity Exchange”, If a client engages in program trading
at more than one exchange, fill out one line for each exchange. The information provided
here cannot be altered later.
10. Trading Code Type: This box can be left blank.
11. Client Trading Code: The
trading code of the client at the ZCE. This information cannot be altered
later.
12. Program Trading Software: Select the full name of the
software. Multiple selections are permitted from the given list. If “Other” is
selected, then “Other Program Trading Software” must be filled out or the form
cannot be uploaded.
13. Other Program Trading
Software: This box is mandatory if “Other” is selected for “Program Trading
Software.” In this case, fill in the name of the software (version number is
optional) or the form cannot be uploaded.
14. Software Developer:
Indicate the full name of the company that developed the program trading
software. If there is more than one developer, separate them with a
(half-width) semicolon (“;”). For a self-developed software, provide the names
of the individual developers.
15. Basic Software Features:
Select one or more of the features listed below as applicable. If “Other” is
selected, then “Additional Feature Descriptions” must be filled out or the form
cannot be uploaded.
The
feature choices are: Automated Opening/Closing Positions, Take Profit/Stop
Loss, Batch Order Placement, Multi-Account Management,Arbitrage,Trading Model
Creation, One-Click/Quick Order Placement, Intraday Trading, Other.
16. Additional Feature
Descriptions: This box is mandatory if “Other” is selected for “Basic
Software Features.” In this case, provide additional descriptions for the basic
features of the program trading software or the form cannot be uploaded.
17. Order Execution Method:
Select one or more options from the given list on how client orders are
executed for program trading. The choices are “Automatic Order Placement,”
“Manual Order Placement,” and “Other.” If “Other” is selected, then “Additional
Method Descriptions” must be filled out or the form cannot be uploaded.
18. Additional Method
Descriptions: This box is mandatory if “Other” is selected for “Order
Execution Method.” In this case, provide additional descriptions on how orders
are executed or the form cannot be uploaded.
19. Terminate Program Trading:
Select “Yes” when the client no longer engages in program trading. For
first-time filers, the default value is “No” and cannot be changed.
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