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A Letter from Alex Breitinger of Paragon Investments on CME Market Data Fee Increase

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NIBA
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As a director of an IB, my greatest concern is that our clients get good value for their money.

With transaction fees increasing by as much as 20%, I would expect that the CME would provide a similar increase in value for the customers. I fear that this is simply going to be an increased source of revenue without a corresponding increase in service.

To that end, I would ask the CME to justify these increases to our (and the CME's) customers. Without such justification, I would expect that customers will push back against the fee increases, which will have to come from FCM's & IB's pockets, hurting their ability to grow the customer base that is the primary source of the CME's revenue.

On the subject of market data fees, I am even more concerned about how limiting access to market data could severely hamper CME & brokerage trading volumes and revenue. Should the CME attempt to extract higher fees for market data, it will certainly curtain volumes, thereby hurting the entire industry that is still reeling from the damage of the past few years.

Respectfully,

Alex Breitinger
Paragon Investments

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