Quote from mats:
thanks rufus,
could you please inform me why I would receive this penalty. I understood that you would get the penalty for 3000 messages or more.
Furthermore I would like to know what would be the policy of CME when these trades/messages take place before regular trading hours. (if I understand correct from CME there are no exact rules during non RTH).
by the way, its great you answered some of my questions, thanks
It is correct that during non-RTH (other than 7-4), the policy won't apply. It is not just the 3000 active message rule, it is the per product volume ratio rule.
Let's take ES for instance, the ratio is 5 :1, so you need a fill of 1 contract for every 5 messages (note new, cancel and modify each counts as an individual message), if you exceeded the ratio greatly. Like in your example, you sent 2999 messages, get a 2 lot fill (only), so your ratio is 1500 : 1 (actually maybe higher since you would needto cancel), which far exceeds the 5:1 ratio, therefore you (actually your clearing firm) would receive a "notice", three strikes (2 notices) and you will be getting a 2k fine.
See the actual policy here.
http://www.cme.com/files/CMEMessagingPolicy.pdf
The per product benchmark here:
http://www.cme.com/files/benchmarks.pdf
While the policy is not specifically targeted at Automated Trading Systems (ATS), but at even 5 : 1, it will just weed out the small ATS (and the small noise-traders that just put on a pile of one-lot orders) that throws a tonne of 1 lot orders on the book, hope one of them would get filled.
Of course, a large ATS, say throwing 2000 orders of 50 lots each, and get filled on just 20 orders won't be affected (don't forget the 1980 cancellations, or cancel and replaces!), since the volume ratio is (2000 + 1980) / (50 * 20) or 4:1 which is below 5:1.