WHEREAS, we believe in full disclosure of CME Group’s (“CME”) lobbying activities and expenditures to assess whether CME’s lobbying is consistent with its expressed goals and in shareholder interests.

RESOLVED, the shareholders CME request the preparation of a report, updated annually, disclosing:

1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.

2. Payments by CME used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.

3. Description of management’s and the Board’s decision-making process and oversight for making payments described in section 2 above.

For purposes of this proposal, a “grassroots lobbying communication” is a communication directed to the general public that (a) refers to specific legislation or regulation, (b) reflects a view on the legislation or regulation and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation. “Indirect lobbying” is lobbying engaged in by a trade association or other organization of which CME is a member.

Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.

The report shall be presented to the Audit Committee or other relevant oversight committees and posted on CME’s website.

SUPPORTING STATEMENT

CME spent $17,795,000 from 2011 – 2020 on federal lobbying. These figures do not include state lobbying expenditures, where CME also lobbies but disclosure is uneven or absent. For example, CME’s lobbying in Illinois over tax breaks has previously attracted attention.4 And CME also lobbies abroad, spending between €200,000 – 299,999 on lobbying in Europe for 2019.

Companies can give unlimited amounts to third party groups that spend millions on lobbying and often undisclosed grassroots activity, and these groups may be spending “at least double what’s publicly reported.”5 CME serves on the board of the International Swaps and Derivatives Association. CME also belongs to Securities Industry and Financial Markets Association (SIFMA), which has spent $71,990,000 on lobbying from 2010 – 2020. CME does not disclose its memberships in, or payments to, trade associations and social welfare organizations, or the amounts used for lobbying, including grassroots. Grassroots lobbying does not get reported at the federal level under the Lobbying Disclosure Act, and disclosure is uneven or absent in states.

We are concerned that CME’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions or takes controversial positions. For example, CME is committed to the integrity our markets, yet CME and SIFMA lobbied to reduce the capital holding requirements derivatives clearing banks must hold against risks,6 which advocates warn increases the risk of a public bailout of a major derivatives clearinghouse. And while polls show support for wall street tax on trades,7 CME and SIFMA were two of the top ten groups lobbying against a financial transaction tax in 2019 and 2020.8

We urge CME expand its lobbying disclosure.

4 https://www.chicagotribune.com/business/ct-xpm-2011-11-09-ct-biz-1109-cme-lobbying-confidential- 20111109-story.html.

5 https://theintercept.com/2019/08/06/business-group-spending-on-lobbying-in-washington-is-at-least-double- whats-publicly-reported/.

6 https://prospect.org/power/wall-street-ally-next-in-line-to-lead-committee-overseeing-derivatives/.

7 https://theappeal.org/the-lab/polling-memos/poll-majority-of-voters-support-the-wall-street-tax-act/. 8 https://www.citizen.org/article/hypnotized-by-wall-street/.