CME · CIK 1156375
What CME Group Inc. told the SEC could break it.
CME's disclosures center on a simple dependency: as an exchange and clearinghouse, its transaction and clearing fees rise and fall with trading volume, which in turn is driven by market volatility — 2025 volumes rose 6% on elevated volatility, but a sustained drop in volatility or a shift in how participants trade would cut revenue. It is also exposed to law and policy changes, including tariffs, tax-policy shifts and restrictions on its ability to offer products in certain geographies or to certain customers, or changes in the underlying physical product flows its markets reference. A smaller, demand-sensitive piece is market data and information services, about 12% of total revenue.
3 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Other disclosures
- revenue dependence on trading volume and market volatilitymedium
CME's transaction- and clearing-fee revenue depends on average daily trading volume across its product lines (interest rates, equity indexes, FX, energy, ag, metals), which is in turn driven by market volatility; 2025 volumes rose 6% on elevated volatility, but a significant change in how participants trade or a decline in volatility/volume would reduce revenue.
“Market liquidity - or the ability of a market to absorb the execution of large purchases or sales quickly and efficiently - is key to attracting and retaining customers and contributing t[o]”
SEC filing →As of 2026
Regulatory & policy
- regulatory/policy changes, tariffs, and geographic/customer restrictions on offering productsmedium
Changes in laws or government policies — including regulatory changes requiring more financial/operational resources, tariffs and tax-policy changes, and restrictions on CME's ability to offer products/services in specific geographies or to specific customers, or limits/changes in underlying physical product flows across geographies — could adversely affect CME's business.
“as well as the impact of tariffs and tax policy changes, restrictions on our ability to offer CME Group products and services in specific geographies or to specific customers or limitations or changes in underlying/physical product flows across geographies”
SEC filing →As of 2026
Customer concentration
- market data & information services = 12% of total revenue, demand-sensitivelow
Market data and information services represented 12% of CME's total revenues in 2025 and 2024; demand depends on economic conditions, regulatory changes and how market participants trade and use market data, so a significant shift could reduce this revenue stream.
“Revenues from our market data and information services represe nted 12% of our total revenues during the years ended December 31, 2025 and December 31, 2024.”
SEC filing →As of 2026
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings, including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its customers
“We rely on third-party market infrastructure providers, including Wedbush Securities Inc. (“Wedbush”) in its capacity as our futures commission merchant (“FCM”) and Chicago Mercantile Exchange Inc. (“CME”) and Crypto.com | Derivatives North America (“CDNA”), each in their capacities as the DCMs on which our prediction markets are listed and derivatives clearing organizations (“DCO”) that clear and settle such contracts.”
Cited →
Its suppliers
Fixed Income Clearing Corporation (FICC, a DTCC subsidiary)
“products, including CME Group SOFR futures, Ultra 10-Year U.S. Treasury Note futures and Ultra U.S. Treasury Bond futures, with FICC-cleared U.S. Treasury notes and bonds and certain repo transactions. We are working with FICC to receive regulatory approval to extend the existing cross-margining arrangement”
Cited →
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