Dec 29, 2025 CME Filing and Examiner Guidance Highlight Tick Size Compliance Issues in NYMEX Oil ContractsHTT and WTT markets under scrutiny as CME prepares rule changes and tightens expectations around box trade pricingA recent CME Group filing submitted to the Commodity Futures Trading Commission (CFTC) on November 19, 2025 proposes amendments to contract size and minimum price increments across several NYMEX oil products, including HTT and WTT. The submission—CFTC Filing No. 25-393—would effectively halve the current minimum tick size for these markets once approved.Because the filing was submitted during the federal government shutdown, it is currently listed as postponed, leaving the minimum tick structure unchanged until the CFTC completes its review.Turnkey Insight: Direct Dialogue with CME ExaminersDuring recent regulatory outreach discussions with CME examiners, in which Turnkey Trading Partners participated, exchange staff outlined their evolving expectations regarding:negotiation language,block trade execution structure, andthe forthcoming reduction in minimum tick size.These conversations provided firsthand clarity on how CME intends to enforce minimum price increment rules in HTT and WTT markets.Turnkey’s direct engagement in these discussions ensures that we are:among the first to receive evolving regulatory interpretations,aware of supervisory priorities before formal notices are issued, andable to advise clients proactively rather than reactively.This insider perspective is already shaping CME surveillance, Market Regulation Advisory Notice (MRAN) updates, and enforcement focus going into 2026.CME Examiner Guidance: Off-Tick Negotiation Under ScrutinyAccording to CME staff, a recurring issue has emerged in HTT and WTT markets: negotiations and communications were frequently occurring at a “half-tick” level, below the minimum price increment.CME emphasized that even if final execution prices are reported on-tick by splitting the trade, the negotiation and communication itself must occur at valid increments. Guidance referenced existing MRAN language addressing block trades and minimum price requirements.The core message: a block trade cannot be executed or negotiated below the minimum increment.To achieve a midpoint price such as 12.5, CME expects communications reflecting:half the quantity at 12half the quantity at 13not a direct reference to 12.5.Why Box Trades Are the FlashpointCME examiners noted that this issue arises primarily in box structures, where:multiple legs carry different tick sizespricing is negotiated on a net package basismarket makers optimize total economics rather than individual leg pricingThis creates a structural problem: many negotiated net prices cannot be expressed on-tick across all legs simultaneously.When market makers request a small improvement—e.g., $0.005—brokers may find it:mathematically impossible to distribute that value on-tick whilekeeping the net economic outcome intactAs a result, market makers frequently push for: “just quote it at the half tick” to preserve the negotiated box price.CME views this as non-compliant, even when execution is later split.CME’s Position Going ForwardExaminers indicated that:negotiation language must reflect valid minimum incrementstrades must be communicated as independent executionsquantities must meet minimum block thresholdssurveillance will focus on both communications and executionImportantly, CME noted that forthcoming updates to MRAN language are expected to:shift some responsibility onto liquidity providers to avoid bidding or offering at non-tradable increments in the first place.This represents a notable change from prior language, which placed most of the burden on brokers.Connection to the November FilingCME acknowledged that HTT and WTT markets have been amenable to trading below the minimum increment with frequency, leading CME business lines to support a formal reduction in tick size to align rules with actual market behavior.The November filing seeks to:reduce minimum price increments (effectively halving them)standardize price gridsreduce the mathematical conflicts that drive off-tick box pricingHowever, until CFTC approval:the existing tick structure remains enforceableoff-tick negotiation is prohibitedsurveillance focus will remain elevatedPractical Impact of Halving the Tick SizeWhile the proposed reduction in minimum tick size is intended to align rulebook increments with actual trading behavior, the change carries both benefits and challenges for brokers and liquidity providers.On the positive side, a smaller tick increment would:make midpoint pricing (e.g., 12.5) a valid, on-tick quoteeliminate many of the mathematical conflicts that currently drive off-tick box pricingreduce the need for brokers to choose between economic accuracy and rule compliancelessen examiner scrutiny tied to negotiation languageFrom a compliance perspective, the change would significantly reduce regulatory exposure by allowing pricing conventions that the market is already using to occur within the rule framework.However, a smaller tick size also introduces commercial and operational consequences, including:tighter spreadsincreased competitive pressure during negotiationreduced pricing cushion for brokersmore granular price movements expected by market makersIn voice-brokered markets, this may result in:more back-and-forth to reach agreementgreater pressure to improve quotesthinner economics on certain structuresIn short:halving the tick size is likely to reduce compliance friction and off-tick violations, but may simultaneously make pricing negotiations more competitive and operationally demanding for brokers.Implications for Brokers and FCMsThe recent examiner guidance reinforces that compliance responsibility ultimately sits with the broker or execution desk, meaning firms may face:increased scrutiny of voice brokerage communicationsinquiries regarding negotiation languagesurveillance flags tied to box trade pricingreview of supervisory controlsEven if market makers request off-tick pricing, brokers are expected to ensure compliant communication.What This Means for Compliance ProgramsFrom a compliance standpoint, the takeaway is clear, supervisory personnel should be communicating to brokers and execution staff that CME is now actively scrutinizing negotiation language tied to minimum tick rules.CME highlighted that:surveillance now reviews communications, not only final reported pricesreferencing non-tradable increments may be treated as a violationCompliance programs should:brief brokerage and execution staffupdate supervisory procedures and training materialsincorporate tick-compliance considerations into communications reviewdocument supervisory outreachTurnkey’s direct involvement in examiner discussions allows us to alert firms to this shift before it appears in formal enforcement actions or widely circulated MRAN updates, supporting a proactive supervisory posture.OutlookThe convergence of:a pending rule change to halve minimum tick sizeselevated examiner scrutiny of off-tick negotiationfuture MRAN updates shifting responsibility toward market makersstructural pricing challenges in box tradesdirect examiner guidance received through Turnkey participationsignals a coordinated push to improve consistency, auditability, and rule adherence in NYMEX oil pricing.Where to Monitor UpdatesCFTC Filing No. 25-393 “Amendments to Contract Size and Minimum Price Increments” https://www.cmegroup.com/content/dam/cmegroup/market-regulation/rule-filings/2025/9/25-393.pdf