*1,What is the role of INE as a central counterparty (CCP)?

As a Central Counterparty (CCP), INE will interpose itself between counterparties upon execution of a futures trade, becoming the seller to the buyer and the buyer to the seller, adopt the net settlement method, and ensure all settlement and delivery for centralized futures trading. Furthermore, the General Exchange Rules of INE provide that the legal attributes of property rights derived from activities such as trading, clearing and delivery of executed orders, positions closed, cash received as margin, assets either pledged or transferred as margin collateral, standard warrants paired for delivery, or those actions adopted by the Exchange against any default event, shall not be revoked or considered null and void due to initiation of bankruptcy proceedings against any Member, and that in the event that a Member enters into a bankruptcy proceedings, the Exchange may still conduct net settlement for such Member's positions in accordance with the General Exchange Rules and the other specifically related rules.

*2,How will INE strengthen its risk management systems to support the globalized futures market?

INE will strictly implement measures that have been proven effective in China's other futures markets, such as pre-margining, One-Trader-One-ID coding policy, position limits, and large trader reporting. In addition, given the different risk profile of overseas traders and the new trading framework of crude oil futures, INE has adopted robust Know Your Customer procedures, including the trader's identity authentication system, ownership & control reporting, and strengthen the management of customer fund segregation and the closed circuit cash flow of margin fund. INE will also work with overseas futures regulators to establish joint regulatory mechanisms to develop effective cross-border supervision and to enable investigation of suspicious trading activity.

*3,What contract months are listed for trading for China's crude futures? How is it different from other international markets?

*4,What is the last trading day and delivery period of China's crude oil futures contract? How do they differ from those of overseas contracts?

*5,How do the daily trading hours of China's crude oil futures differ from those of major international crude oil futures contracts?

CME WTI on Globex: Sunday to Friday 18:00－17:00 (+1 day) New York Time/ET, with a 60-minute break each day beginning at 17:00 ET. ICE Brent: Sunday to Friday 20:00－18:00 (+1 day) New York Time; 01:00－23:00 London Time; and 08:00–06:00 (+1 day) Singapore Time. DME Oman: Electronic trading is open from 16:00 CST/CDT Sundays and from 16:45 CST/CDT Monday to Thursday and closes at 16:00 CST/CDT the next day, Monday to Friday. INE Crude Oil Futures: Monday to Friday 9:00－11:30, 13:30－15:00 Beijing Time and other trading hours (Continuous Trading Hours) as prescribed by the INE. INE will continue to observe the needs for extension of trading hours for the market development.

*6,What is the trader eligibility criteria for overseas institutional customers to participate in China's crude oil futures market and how may eligible overseas traders trade on the Exchange?

Any overseas institutional investor intending to participate in China's crude oil futures market should meet the requirements set in the Futures Trading Participant Eligibility Management Rules of the Shanghai International Energy Exchange, including but not limited to the following: having relevant business professionals who understand the essentials of futures trading and the rules of INE and have passed relevant tests; having futures trading history and record; having a cash balance of no less than RMB 1 million or its foreign currency equivalent in its margin account last for more than five business days before applying for a trading code; having in place sound futures trading management rules; having no material adverse credit record and not banned from the futures 79 95 80 market by competent regulatory authority; having never been prohibited or banned from engaging in trading futures pursuant to any laws, rules and regulation of China or rules of INE . All Eligible traders need to abide by the laws and regulations of China, the rules of INE, as well as the laws, regulations, and regulatory rules of their home jurisdiction. INE encourages investors and oil-related commercial clients to engage in hedging trades in China's crude oil futures market. Overseas investors may participate in China's crude oil futures market using any of following accesses: (a) Global customer may trade through a domestic Futures Firm (FF); (b) An INE-recognized Overseas Intermediaries may help its global customers execute and clear trades through a carry broker, either a domestic FF or an Overseas Special Brokerage Participant (OSBP); (c) An INE OSBP having direct trading right on the Exchange may help their global customers execute trades on the Exchange; or (d) an Overseas Special Non-Brokerage Participants (OSNBP) of INE that trades directly on the Exchange.

*7,How may overseas futures brokers participate in China's crude oil futures market?

An overseas futures broker may either apply to the INE to be an OSBP and direct connect to the Exchange for execution of trades or execute trades and clear through a carry broker who is either a domestic FF Member or an OSBP on behalf of its overseas customers.

*8,How may overseas individual investors participate in China's crude oil futures market?

Any overseas individual investor intending to participate in China's crude oil futures market should meet the requirements set in the Futures Trading Participant Eligibility Management Rules of the Shanghai International Energy Exchange, including but not limited to the following: having full capacity for civil conduct; understanding the essentials of futures trading and the rules of INE; having passed relevant tests; having futures trading history and record; having a cash balance of no less than RMB 500,000 or its foreign currency equivalent in his/her margin account last for more than five business days before applying for a trading code; having no material adverse credit records and not banned from the futures market by competent regulatory authority; having never been prohibited or banned from engaging in futures trading pursuant to any laws, regulations, and rules of China or any rules of INE. All Eligible traders need to abide by the laws and regulations of China, the rules of INE, as well as the laws, regulations, and regulatory rules of their home jurisdiction. An overseas individual investor may participate in China's crude oil futures market through a domestic FF Member, an OSBP, or an Overseas Intermediary.

*9,Is it required for those investors, who are under the jurisdiction of Europe and participating in China's crude oil futures market through an European Overseas Intermediary, to register to relevant authority for participation of overseas futures market by observing the European Market Infrastructure Regulation (EMIR)?

According to the guiding principle given by the CSRC, INE prioritized and have completed the analysis work about crossborder regulation of Hong Kong, Singapore and the United States on participation in overseas futures market. The Exchange has launched further regulation study on overseas futures market participation of other global financial trading hubs. 84 99 There are many countries and financial regulators in the region of Europe or under the league of European Union (EU). Thus an European participant may face double layers of regulation from its jurisdiction as well as from the European Securities and Markets Authority (ESMA) when participating the China crude futures trading, It's highly recommended to such participant to provide information about his/her nationality and desired participation mode on INE, so that the Exchange may conduct relative regulation study and provide advice accordingly.

*10,What's the requirement on money exchange offshore participants in the crude futures trading?

The crude futures on INE is denominated in Renminbi (RMB) and it's cleared and settled in RMB as well. For offshore investors and qualified overseas brokers, they are allowed to post cash in RMB or USD as margin. During the daily clearing and settlement cycle, the USD cash will be exchanged to RMB for mark to market, if a trading account's daily mark-to-market result is in a loss and the RMB balance is not sufficient to cover the loss. Any purchase and sales of foreign exchange shall match the crude futures' trading result of an offshore traders or a qualified overseas brokers. The money exchange can only be executed for mark to market for crude futures trading, futures trading related fees, physical delivery, and other money exchange needs related to cruder futures trading.

*11,What's the flow of inbound/outbound fund transfer for crude oil futures trading?

According to the PBOC Circular [2015] No.19 of People Bank of China (PBOC) and the circular of Huifa [2015] No. 35 of the State Administration of Foreign Exchange (SAFE), offshore investors and overseas brokers may remit offshore RMB or USD to onshore specific-purpose bank account to participate the crude futures trading. Such funds shall be placed in segregated accounts and isolated from unauthorized access and operations while they are within China, and may not be used for any purpose other than futures trading. Remittance of fund in a specific-purpose bank account shall observe the scope of receipts and payments as prescribed in relevant policies.

*12,Is it necessary for an FX for the futures trading be conducted in a Designated Depository Bank? Can FX be conducted in one bank that offer better rate and then transferred into the account of the designated depository bank account that such customer has account with?

Money Exchange for futures trading must be conducted in a Designated Depository Bank. When an Exchange Member conducts money exchange, it may check rates offer by different Designated Depository Banks and choose the one with best bid/ offer rate to conduct the money exchange.

*13,How does China's crude oil future contract differ from other major crude oil futures contracts in the world in terms of the price limit?
A price limit of 4% (minimum limit) above or below the preceding day's settlement price. The Exchange may, in its sole discretion, adjust the price limit for such futures contract in response to market risk conditions. In general, international markets either do not prescribe a price limit, or implement a lenient one to complement circuit breakers. There is no price limit for ICE Brent crude futures and DME Oman crude futures. For WTI crude futures contract, there is a initial price fluctuation limit of $5 above or below the settlement price of the previous day. When price limit is hit, trading will halt for 2 minutes. Upon resumption price limit will be set to twice the original value, and a total of 4 escalation level with five dollar increment at each level. After the fourth level price limit is hit, the circuit break will be exempted for the day. 

*14,What is the margining methodology for the China's crude oil futures market? How is it different from that for major crude oil futures in the world? 

INE applies pre-margining. The Exchange applies different rates of trading margin for a futures contract based on different periods of trading from its listing to its last trading day. The Exchange may, in its sole discretion, adjust the price limit for a futures contract in response to market risk conditions and it shall issue a public announcement of the adjustment. The management of Clearing Deposit shall be managed in accordance with the Clearing Rules of the Shanghai International Energy Exchange. Both the ICE Clear of ICE Europe and the Clearing House of CME Group use CME's proprietary margining system – the Standard Portfolio Analysis of Risk (SPAN) system. The system calculates the initial margin requirement by organizing all positions which share the same ultimate underlying to grouping referred to as a "Combined Commodity Group" and calculating and aggregating, by like scenario, the risk of each position (including in the price volatility of different contract positions) within a Combined Commodity, with that scenario generating the maximum theoretical loss . As a result and which also meets the needs of clearing member's netting settlement procedure, the level of initial margin can be minimized without putting clearing houses at unreasonable risks, ensuring capital-efficiency in futures market. As of year 2017, the margin requirement of ICE Brent contract is around $2,700－$3,700 set by the ICE Clear. For CME WTI contract, the requirement is $2,700 of initial margin and $2,300 of maintenance margin per nearby month contract, progressively reduced for contract months further out. DME clearing and settlement is provided by the Clearing House of CME Group, and requires $4,750 of initial margin and $3,750 of maintenance margin per an Oman contract.

A member can submit the fund remit request on the INE's Member Service System, using the function of electronic fund transfer, for fund transfer in between such Member's margin account and the Exchange clearing account. Fund remit instruction into the Exchange's clearing account during market hours will be automatically processed in real time. For fund withdrawal instruction from the Exchange's clearing account, it will only be processed after daily clearing and settlement on the same day.

*16,Can a domestic/overseas broker provide financing service to its customers in futures trading?

An overseas broker shall conduct its business in accordance the rules and regulation of its jurisdiction. As for domestic futures brokers, they shall follow the policy and regulation of the CSRC.

*17,Is it required for an offshore institutional investor who trade on INE through an onshore/offshore broker to set up an specified bank account for futures trading purpose? 

If an offshore institutional investor, either a futures trader or a brokerage firm, trade on INE though a domestic broker, it's required for such investor to set up a specified bank account for futures trading purpose with a designated depository bank for margin depository business of its overseas clients.

The table below lists current Designated Delivery Storage Facilities for crude oil futures (capacity unit: 10,000 M3 )

*1,What conditions shall an overseas broker satisfy to entrust a futures company member with the business of trading specified domestic futures products？ 

Being a financial institution legally registered and incorporated overseas, and having been recognized by the futures regulatory agency of the country (or region) where it is located to be qualified to accept the traders' funds and trading orders to carry out the futures trading on behalf of such investors; Having operated for at least one (1) year; The futures regulatory agency of the country (or region) where it is located has entered into a regulatory cooperation memorandum of understanding with CSRC; Having sound governing institutions and internal control policies, having normal and regular operations; Having the net capital no less than CNY thirty million (30,000,000.00) or an equivalent amount in foreign currency; Having the business facilities and technical systems which comply with the applicable technical norms and are in good operation condition; and other conditions prescribed by DCE.

*2,What are the paths for overseas traders to participate in the domestic iron ore futures? 

During the preliminary period of opening to the outside, there are two methods for overseas traders to participate in the iron ore futures: (i) to directly participate in trading through a domestic futures company; and (ii) to participate in trading through an overseas broker entrusted by a domestic futures company. 

*3,What are the DCE’S traders’ suitability requirements for domestic and overseas traders in trading specified futrures products? 

The Measures for Management of Suitability of Traders of Specified Domestic Futures Products of Dalian Commodity Exchange provides for knowledge test, available funds, trading experiences and other requirements for suitability for the corporate clients and individual clients. Any futures company member or overseas broker (Account-opening Institution) shall assess the Traders' knowledge levels and risk tolerance capability of futures and prudently choose the suitable traders to participate in trading specified domestic futures products. 

*4,What are the requirements in funds for the clients that participate in trading specified products?

The balance of the available funds is not less than CNY one hundred thousand (100,000) or equivalent foreign currency at the margin account after the daily settlement for each of the five (5) trading days prior to the client's application for the trading code or the granting of the trading authority. The balance of the available funds at the clients’ margin accounts shall be calculated on the basis of the margin standards collected by the Account-opening Institutions. The balances in CNY and in foreign currency shall be added up upon calculation. 

*5,What are the requirements in knowledge test for the clients that participate in trading specified products?

The client shall log in China Futures Association's examination platform to sit for the online knowledge test in Chinese or English. Scoring Eighty (80) and higher out of the total one hundred (100) points in the knowledge test will be qualified. The knowledge test shall be completed solely and independently during the whole course by the individual client or the order-placer specified by the institution client other than by any other person. The Account-opening institutions shall strictly verify the clients' identity, and the relevant persons of the Account-opening Institutions and the clients shall sign on the score sheets. A new examination will be necessitated in case of any change in the order-placer. 

*6,What are the requirements in trading experience for the clients that participate in trading specified products? 

Regarding domestic futures trading experiences: The client shall provide the futures trading settlement bills issued by the futures company members to certify that it has the valid trading records of the futures or option at a domestic exchange for the recent three (3) years. Regarding overseas futures trading experiences: The client shall provide the detailed futures records, the settlement bills or other certification at an overseas futures trading venue which is under regulation by the futures regulatory institution of the country (region) which has entered into a Memorandum of Understanding of Cooperation with the CSRC, to certify that it has the valid trading records of the futures or option for the recent three (3) years. 

*7,What are the account opening methods for overseas traders? 

Currently, there are two methods: one is direct account-opening method, that is, the client opens an account through a domestic futures company which then applies on the client's behalf for the trading code through China Futures Market Monitoring Center Co., Ltd. (CFMMC)'s uniform account-opening system. The other is sub-delegated account-opening method, that is, the client opens an account through an overseas broker which is filed at DCE and which then entrust the futures company to carry out the trading of the specified domestic futures products. During the sub-delegated account-opening process, the overseas broker shall apply on the client's behalf for the trading code through the CFMMC's uniform account-opening system, and the domestic futures company shall carry out certain management and control, however, without checking the overseas trader's personal information. The overseas client that opens accounts by taking both the above methods shall not carry out the futures trading through the same futures company Member. The one that opens accounts through different overseas brokers shall not entrust the same futures company Member with the futures trading. 

*8,What identity certification materials shall be submitted when the overseas client opens an account? 

Upon opening an account, the overseas trader shall submit valid identity certification documents and at least one (1) reference identity certification document. If the overseas entity client authorizes an account-opening agent to handle the account-opening formalities, it shall issue the power of attorney or other authorization documents, valid identity certification documents of its standing director(s) or statutory representative, other reference identity certification documents, account-opening agent's identity certification documents and other account-opening materials. Please refer to the CFMMC's Uniform Account-opening Business Operation Rules for Overseas Traders for the specific requirements for the relevant materials. 

*9,What is trading code? 

The trading code shall refer to the special code used by the client to carry out futures trading; and after the passing of the client's account-opening application, DCE will assign to it a trading code. The client trading code consists of a 12-digit number, the first four digits being the member number and the remaining eight digits being the client number. With respect to the overseas client whose account is opened under the sub-delegated model, the member number shall refer to the member number of the futures company entrusted by the overseas broker. One client can have only one client number in DCE but may have more than one trading code due to the fact that it opens accounts through different members. 

*10,Can the overseas brokers directly access and trade at DEC?

Currently, no. With respect to the DCE's futures products which have been determined by the CSRC to be specified domestic products, the overseas broker may enter into a written entrustment agreement with the domestic futures company member which then file an application to DCE for the sub-delegation business filing; and thus, the overseas broker may carry out trading through the domestic futures company member.

 *11,How does the futures company member clear with the overseas broker?

The futures company member may open a comprehensive account for the overseas broker to be used for the futures settlement, delivery and other matters of the overseas clients of the overseas broker. The futures company member shall collect margins as per the comprehensive account until registration of the subsidiary accounts to (the comprehensive funds account of) the overseas broker. 

*12,How can overseas traders receive the DCE’s detailed price quotation?

Currently, Dalian Futures Information Technology Co., Ltd. (DFIT), the subsidiary wholly owned by DCE, is responsible for the external license service regarding the detailed price quotation:(i) Forwarded by information suppliers. The overseas traders may view the detailed quotation through the licensed information suppliers' client-side products. DCE's level-2 display quotation information suppliers include Interactive Data, Fidessa, Wenhua Finance & Economics, Shanghai Pengbo and Guotai'an. Interactive Data also owns the forwarding qualification regarding the overseas non-display use, and the traders may purchase the data-feed service through forwarding.(ii) DFIT direct-connection service. This mainly targets the users of non-display quotation demands. The overseas traders may use such service to carry out trading strategy research or implementation, risk control or other uses. Currently, the Datafeed data products provided by DFIT is a direct-connection service, and the clients may use the co-location method to receive the DCE's detailed quotation directly through the API interface provided by DFIT, thus avoiding the delay of any data acquired through an information supplier.

PTA futures Q&A

*1, An overseas broker appointing an FB member with futures trading business on behalf of itself shall meet the following requirements:

(1). being a financial institution legally registered and established outside the territory of the PRC, and having been qualified by local regulatory authority to accept its clients’ funds and trading orders to conduct futures trading in its own name; (2). having operated for more than one (1) year; (3). accepting the supervision by local regulatory authority which has signed a Memorandum of Understanding on regulatory cooperation with the CSRC; (4). having sound corporate governance structure and internal control system, and having normal and regular operations; (5). having net capital of no less than CNY 30 million or an equivalent amount in foreign currency; (6). having the business facilities and technical systems which comply with the applicable technical standards and are in sound operation condition; (7). other requirements prescribed by the Exchange.

*2, An FB member shall enter into a written appointment agreement with its overseas broker. The appointment agreement shall contain the following terms:

(1). scope of appointment; (2). minimum margin rate, and the procedure and service charge rate for pledging relevant assets as margin; (3). measures, conditions and procedures of risk management; (4). types and management mode of client accounts, and clearing procedure; (5). rates of service charges; (6). use of information and confidentiality issues; (7). matters, means and time limits of notice; (8). measures that could ensure the safety and stability of data transmission; (9). cooperation procedures and rules with respect to trading, clearing, delivery, funds management, quotes, trading system configuration, client service, risk control, etc.; (10). recourse of losses arising from the forced position liquidation; (11). circumstances under which losses are not attributable to either party and the solutions to such situations; (12). amendment to or termination of the agreement; (13). liability for any breach of the agreement; (14). methods of settling disputes and jurisdiction sovereignty; (15). application of law; (16). other matters required by the Exchange.

*3, The institutional clients participating in the trading of specified futures products shall meet the following requirements: 

(1). their relevant business personnel shall have basic knowledge of the futures market, understand the Exchange’s business rules of specified products and have passed relevant tests approved by the Exchange; (2). after daily settlement for five (5) consecutive trading days before applying for trading codes and permissions, the balance in their margin accounts shall be no less than CNY 100,000 or equivalent amount in foreign currency; (3). shall have no less than one futures trading record for recent three (3) years in any of the futures exchange within the territory of the PRC or the overseas futures trading venue, and these overseas futures trading venues shall be located in the countries or regions that have signed MOUs on regulatory cooperation with China Securities Regulatory Commission (hereinafter “the CSRC”); (4). shall have established internal control system, risk management system and other relevant system for futures trading, and shall have established sound reporting system that could provide and timely update the information about their department heads and other relevant business personnel in charge of futures trading to their account-opening institutions; (5). shall not have severely negative credit history or be prohibited from entering the futures market by regulatory authorities; (6). shall not be prohibited or restricted by any law, administrative regulation, rule or business rule of the Exchange from engaging in futures trading; (7). other conditions prescribed by the Exchange.

*4, The individual clients participating in the trading of specified futures products shall meet the following requirements: 

(1). shall have full capacity for civil conduct; (2). shall have basic knowledge of the futures market, understand the Exchange’s relevant business rules for specified futures products and have passed relevant tests approved by the Exchange; (3). after daily settlement for five (5) consecutive trading days before applying for trading codes and trading permissions, the balance in their margin accounts shall be no less than CNY 100,000 or equivalent amount in foreign currency; (4). shall have no less than one futures trading record for recent three (3) years in any of the futures exchange within the territory of the PRC or the overseas futures trading venue, and these overseas futures trading venues shall be located in the countries or regions that have signed MOUs on regulatory cooperation with the CSRC; (5). shall not have severely negative credit history or be prohibited from entering the futures market by regulatory authorities; (6). shall not be prohibited or restricted by any law, administrative regulation, rule or business rules of the Exchange from engaging in futures trading; (7). other conditions prescribed by the Exchange.

*5, Basic knowledge test for futures trading taken by clients shall meet the following requirements: 

(1). the clients shall attend the knowledge tests recognized by the Exchange, and the test scores shall not be lower than the standard published by the Exchange; (2). individual clients and the staff appointed by institutional clients to place orders shall attend the tests in person and surrogate test-takers are not allowed; (3). an account-opening institution’s staff responsible for developing clients shall not concurrently be the supervisors of the test. An account-opening institution shall coach and urge its clients to comply with relevant laws, administrative regulations, business rules of the Exchange and relevant regulations and decisions, conduct education on risk management on an on-going basis and strengthen the management of legal and regulatory compliance of its clients’ trading practices.