Background

On 3 January 2018, a new Directive 2014/65/EC (“MiFID II”) and Regulation (EU) No 600/2014 (“MiFIR”) will become effective, introducing new requirements on position limits and position reporting for commodity derivatives and emission allowances.

National Competent Authorities (“NCAs”) (i.e. regulators) of each European Economic Area (“EEA”) Country will calculate the limits on the size of the net position that a person can hold in commodity derivatives traded on an EU venue or its “economically equivalent contracts” (“EEOTC”).

The European Securities and Markets Authority (“ESMA”) intends to publish approved position limits on its website.
Limits will be set for the spot month and all other months, for both physically settled and cash settled commodities.
Investment firms trading in commodity derivatives and emissions allowances are obliged, on a daily basis, to report
their own positions in commodity derivatives traded on a trading venue and EEOTC contracts, as well as those of
their clients and the clients of those clients until the end client is reached, to the NCA.

Clients holding positions have to be identified using specified National Identifiers for individuals and LEIs for
organisations under MiFID II.

Interactive Brokers’ Implementation of the Requirements

In order to comply with its reporting obligations, IB will not allow its clients to trade if they have not provided the
specific National Identifier or LEI that is necessary for reporting positions of in scope financial products.

Whenever possible, IB will act to prevent account holders from entering transactions that may result in a position
limit violation. This process will include monitoring account activity, sending a series of notifications intended to
allow the account holder to self-manage exposure and placing trading restrictions on accounts approaching a limit.

Examples of notifications which are sent via email, TWS bulletin and Message Center are as follows:

1. Information Level: sent when the position exceeds 50% of the limit. Intended to inform as to the existence of the position limit and its level.
2. Warning Level: sent when the position exceeds 70% of the limit. Intended to provide advance warning that account will be subject to trading restrictions should exposure increase to 90%.
3. Restriction Level: sent when the position exceeds 90% of the limit. Provides notice that account is restricted to closing transactions until exposure has been reduced to 85%.
    

What is the trading symbol?

CME (Bitcoin Futures): Enter the underlying symbol BRR in order to bring up the futures

CME (Ether Futures): Enter the underlying symbol ETHUSDRR to bring up the futures

ICE (Bakkt® Bitcoin Futures): Enter the underlying symbol BAKKT to bring up the futures

What are the trading hours?

CME: 17:00 – 16:00 Chicago Time, Sunday – Friday

ICE: 19:00-17:00 Chicago Time, Sunday – Friday

Please note, if you wish to trade outside of regular trading hours or have your order triggered outside of regular trading hours you must configure your order accordingly. You can do so using the following steps:

• Through Futures Order Presets. In Classic TWS, click Edit followed by Global Configuration. In Mosaic, click File followed by Global Configuration. Expand the Presets section on the left side and select Futures. The first section will be Timing, and you will want to check the box that says "Allow order to be activated, triggered, or filled outside of regular trading hours (if available)". Click Apply and OK once finished.
• Through the order line. In both Classic TWS as well as Mosaic, click on the Time in Force field and check the box at the bottom that says "Trigger outside RTH". In WebTrader, check the box at the end of the order line that says "Fill Outside RTH".
• Through the Order Ticket. In the Time in Force section, check the box that says "Allow this order to be filled outside of regular trading hours".

Please see the following link for more information on trading futures outside of regular trading hours:
https://www.interactivebrokers.com/en/index.php?f=719

Where can I find information about the contract specifications?

CME (Bitcoin Futures): http://www.cmegroup.com/trading/bitcoin-futures.html?itm_source=cmegroup&itm_medium=flyout&itm_campaign=bitcoin&itm_content=tech_flyout

CME (Ether Futures): https://www.cmegroup.com/trading/ether-futures.html

ICE (Bakkt® Bitcoin Futures): https://www.theice.com/products/72035464/Bakkt-Bitcoin-USD-Monthly-Futures-Contact

Will there be any restrictions on trading?

Trading will not be offered in retirement accounts (e.g., IRA, SIPP) or for residents of Japan.

What is the Margin Requirement?

The margin requirement for outright long positions will be set at 50% of the prior day's lead month settlement price. In the case of outright short positions, the margin rate will be 100% of the daily settlement price.

Spread Margin: The net difference between the outright customer maintenance margin requirements on each long and short contracts (using 50% for both the long and the short leg) plus, for each spread, a spread charge equal to 25% of the daily settlement price that is the greatest among all XBT futures contracts available for trading.

Clients are reminded that IBKR does not issue margin calls and may modify margin requirements at any time, at IBKR's sole discretion.

Please refer to the following section of the IBKR website for current margin requirements for all products: https://www.interactivebrokers.com/en/index.php?f=24176

What are the commissions?

The commission rate for Crypocurrency futures will be USD 10 per contract for the CME and ICE products. IBKR will pass through exchange, regulatory and clearing fees.

For more information on commission as well as exchange, regulatory and clearing fees, please visit the Commission page of our website:
https://www.interactivebrokers.com/en/index.php?f=commission&p=futures1

What trading permissions are required?

To trade Crypocurrency futures, you must have trading permissions for US Crypto Futures. You can request US Crypto Futures trading permission in Client Portal by clicking the User menu (head and shoulders icon in the top right corner) followed by Manage Account. Click the gear icon in the top right corner of the Trading Experience & Permissions section. Go to the "Futures" section and check off "United States (Crypto)".

What are the market data subscription options?

Live quotes for Crypocurrency futures are available on a paid subscription basis through Client Portal. The following subscriptions are offered (monthly subscription fees are posted to the IBKR website):

CME (Exchange = CME. IB Exchange = CME)

Non-Professional

• Level 1: CME Real-Time Non-Professional Level 1
• Level 1: US Securities Snapshot and Futures Value Bundle (NP,L1)
• Level 2: CME Real-Time Non-Professional Level 2
• Level 2: US Value Bundle PLUS (NP,L2)
  • Requires US Securities Snapshot and Futures Value Bundle
  • This is only for depth of book

Professional

• Level 2: CME Real-Time Professional Level 2 (There is no CME Pro level 1 product)

ICE (Exchange = ICE, IB Exchange = ICECRYPTO)

• Level 2: ICE Futures US - Digital Asset Futures Level 2 (There is no level 1 available for either professional or professional)

Back to Table of Contents: Bitcoin and Other Cryptocurrency Products @ IBKR

Title:

How are executions allocated when an order receives a partial fill because an insufficient quantity is available to complete the allocation of shares/contracts to sub-accounts?

Overview:

From time-to-time, one may experience an allocation order which is partially executed and is canceled prior to being completed (i.e. market closes, contract expires, halts due to news, prices move in an unfavorable direction, etc.). In such cases, IB determines which customers (who were originally included in the order group and/or profile) will receive the executed shares/contracts. The methodology used by IB to impartially determine who receives the shares/contacts in the event of a partial fill is described in this article.

Background:

Before placing an order CTAs and FAs are given the ability to predetermine the method by which an execution is to be allocated amongst client accounts. They can do so by first creating a group (i.e. ratio/percentage) or profile (i.e. specific amount) wherein a distinct number of shares/contracts are specified per client account (i.e. pre-trade allocation). These amounts can be prearranged based on certain account values including the clients’ Net Liquidation Total, Available Equity, etc., or indicated prior to the order execution using Ratios, Percentages, etc. Each group and/or profile is generally created with the assumption that the order will be executed in full. However, as we will see, this is not always the case. Therefore, we are providing examples that describe and demonstrate the process used to allocate partial executions with pre-defined groups and/or profiles and how the allocations are determined.

Here is the list of allocation methods with brief descriptions about how they work.

·         AvailableEquity
Use sub account’ available equality value as ratio. 

·         NetLiq
Use subaccount’ net liquidation value as ratio

·         EqualQuantity
Same ratio for each account

·         PctChange¹:Portion of the allocation logic is in Trader Workstation (the initial calculation of the desired quantities per account).

·         Profile

The ratio is prescribed by the user

Basic Examples:

Details:

CTA/FA has 3-clients with a predefined profile titled “XYZ commodities” for orders of 50 contracts which (upon execution) are allocated as follows:

Account (A) = 25 contracts

Account (B) = 15 contracts

Account (C) = 10 contracts

Example #1:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 10 am (ET) the order begins to execute²but in very small portions and over a very long period of time. At 2 pm (ET) the order is canceled prior to being executed in full. As a result, only a portion of the order is filled (i.e., 7 of the 50 contracts are filled or 14%). For each account the system initially allocates by rounding fractional amounts down to whole numbers:

Account (A) = 14% of 25 = 3.5 rounded down to 3

Account (B) = 14% of 15 = 2.1 rounded down to 2

Account (C) = 14% of 10 = 1.4 rounded down to 1

To Summarize:

A: initially receives 3 contracts, which is 3/25 of desired (fill ratio = 0.12)

B: initially receives 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: initially receives 1 contract, which is 1/10 of desired (fill ratio = 0.10)

The system then allocates the next (and final) contract to an account with the smallest ratio (i.e. Account C which currently has a ratio of 0.10).

A: final allocation of 3 contracts, which is 3/25 of desired (fill ratio = 0.12)

B: final allocation of 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: final allocation of 2 contract, which is 2/10 of desired (fill ratio = 0.20)

The execution(s) received have now been allocated in full.

Example #2:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 11 am (ET) the order begins to be filled³ but in very small portions and over a very long period of time. At 1 pm (ET) the order is canceled prior being executed in full. As a result, only a portion of the order is executed (i.e., 5 of the 50 contracts are filled or 10%).For each account, the system initially allocates by rounding fractional amounts down to whole numbers:

Account (A) = 10% of 25 = 2.5 rounded down to 2

Account (B) = 10% of 15 = 1.5 rounded down to 1

Account (C) = 10% of 10 = 1 (no rounding necessary)

To Summarize:

A: initially receives 2 contracts, which is 2/25 of desired (fill ratio = 0.08)

B: initially receives 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: initially receives 1 contract, which is 1/10 of desired (fill ratio = 0.10)

The system then allocates the next (and final) contract to an account with the smallest ratio (i.e. to Account B which currently has a ratio of 0.067).

A: final allocation of 2 contracts, which is 2/25 of desired (fill ratio = 0.08)

B: final allocation of 2 contracts, which is 2/15 of desired (fill ratio = 0.134)

C: final allocation of 1 contract, which is 1/10 of desired (fill ratio = 0.10)

The execution(s) received have now been allocated in full.

Example #3:

CTA/FA creates a DAY order to buy 50 Sept 2016 XYZ future contracts and specifies “XYZ commodities” as the predefined allocation profile. Upon transmission at 11 am (ET) the order begins to be executed²  but in very small portions and over a very long period of time. At 12 pm (ET) the order is canceled prior to being executed in full. As a result, only a portion of the order is filled (i.e., 3 of the 50 contracts are filled or 6%). Normally the system initially allocates by rounding fractional amounts down to whole numbers, however for a fill size of less than 4 shares/contracts, IB first allocates based on the following random allocation methodology.

In this case, since the fill size is 3, we skip the rounding fractional amounts down.

For the first share/contract, all A, B and C have the same initial fill ratio and fill quantity, so we randomly pick an account and allocate this share/contract. The system randomly chose account A for allocation of the first share/contract.

To Summarize³:

A: initially receives 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: initially receives 0 contracts, which is 0/15 of desired (fill ratio = 0.00)

C: initially receives 0 contracts, which is 0/10 of desired (fill ratio = 0.00)

Next, the system will perform a random allocation amongst the remaining accounts (in this case accounts B & C, each with an equal probability) to determine who will receive the next share/contract.

The system randomly chose account B for allocation of the second share/contract.

A: 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: 0 contracts, which is 0/10 of desired (fill ratio = 0.00)

The system then allocates the final [3] share/contract to an account(s) with the smallest ratio (i.e. Account C which currently has a ratio of 0.00).

A: final allocation of 1 contract, which is 1/25 of desired (fill ratio = 0.04)

B: final allocation of 1 contract, which is 1/15 of desired (fill ratio = 0.067)

C: final allocation of 1 contract, which is 1/10 of desired (fill ratio = 0.10)

The execution(s) received have now been allocated in full.

Available allocation Flags

Besides the allocation methods above, user can choose the following flags, which also influence the allocation:

·         Strict per-account allocation.
For the initially submitted order if one or more subaccounts are rejected by the credit checking, we reject the whole order.

·         “Close positions first”¹.This is the default handling mode for all orders which close a position (whether or not they are also opening position on the other side or not). The calculation are slightly different and ensure that we do not start opening position for one account if another account still has a position to close, except in few more complex cases.

Other factor affects allocations:

1)      Mutual Fund: the allocation has two steps. The first execution report is received before market open. We allocate based onMonetaryValue for buy order and MonetaryValueShares for sell order. Later, when second execution report which has the NetAssetValue comes, we do the final allocation based on first allocation report.

2)      Allocate in Lot Size: if a user chooses (thru account config) to prefer whole-lot allocations for stocks, the calculations are more complex and will be described in the next version of this document.

3)      Combo allocation¹: we allocate combo trades as a unit, resulting in slightly different calculations.

4)      Long/short split¹: applied to orders for stocks, warrants or structured products. When allocating long sell orders, we only allocate to accounts which have long position: resulting in calculations being more complex.

5)      For non-guaranteed smart combo: we do allocation by each leg instead of combo.

6)      In case of trade bust or correction¹: the allocations are adjusted using more complex logic.

7)      Account exclusion¹: Some subaccounts could be excluded from allocation for the following reasons, no trading permission, employee restriction, broker restriction, RejectIfOpening, prop account restrictions, dynamic size violation, MoneyMarketRules restriction for mutual fund. We do not allocate to excluded accountsand we cancel the order after other accounts are filled. In case of partial restriction (e.g. account is permitted to close but not to open, or account has enough excess liquidity only for a portion of the desired position).

Footnotes:

1.        Details of these calculations will be included in the next revision of this document.

2.        To continue observing margin in each account on a real-time basis, IB allocates each trade immediately (behind the scenes) however from the CTA and/or FA (or client’s) point of view, the final distribution of the execution at an average price typically occurs when the trade is executed in full, is canceled or at the end of day (whichever happens first).

3.       If no account has a ratio greater than 1.0 or multiple accounts are tied in the final step (i.e. ratio = 0.00), the first step is skipped and allocation of the first share/contract is decided via step two (i.e. random allocation).