Exhibit A

HEDGE
Street

(g) - (0) [unchanged]
RULES 12.79 — 12.86 [unchanged]
[End Rulebook]

1825 S. Grant Street
Sulte 500

‘San Mateo, CA 94402
Tel: 650.638.3500

www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0100.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout

Criterion of greater than X (rounded to the nearest 0.0025) ~ 0.0075.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0050.

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0025.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025).

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0025.

(8) Binary Hedgelet Contract 8: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0050.

(9) Binary Hedgelet Contract 9: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0075.

(10) Binary Hedgelet Contract 10: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0100.

(11) Binary Hedgelet Contract 11: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0125.

(12) In each case, ‘*X” equals the last USD/CAD price or value
rounded to the nearest 0.0025 as reported by the Source Agency.

(ii) SPOF DAILY USD/CAD BINARY CONTRACTS 8
PM (ET) CLOSE

(1) - (13) [unchanged]

(14) In each case, “X” equals the last USD/CAD sate price or value

rounded to the nearest 0.0025 as reported inthe spet USD/CAD foreign ¥
‘ket-at SPM _ET onthe previeus-busi day by the Source Agency.

#9 (iii) [except for renumeration, this rule is unchanged]

1825 S. Grant Street
Sulte 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www-hedgestreet.com Fax: 650.638.3501


HEDGE
Street

October 4, 2006

VIA EMAIL: secretary@cftc.gov

Ms. Eileen A. Donovan, Acting Secretary
Secretary of the Commission

Commodity Futures Trading Commission
3 Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Rule Certification: HedgeStreet® intends to add new Daily Payout Criteria
in two (2) Binary Currency Contracts — Submission pursuant to
Commission Regulation §40.6(a)

Dear Acting Secretary Donovan:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and
§40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission
(the “Commission”) under the Act, HedgeStreet, Inc. (“HedgeStreet”) hereby certifies with
the Commission its intent to add new Payout Criteria for both the Daily USD/CHF Binary
Hedgelet Contracts and the Daily USD/CAD Binary Hedgelet Contracts (the “Contracts”).
HedgeStreet is also correcting a typographical error in Rule 12.78(f)(ii).

HedgeStreet intends to implement the amendments to the Contracts at the start of business
on Thursday, October 5, 2006.

All amendments to the above-referenced Contracts are defined in Exhibit A. Any rule
deletions are stricken out while the amendments and/or additions are underlined.

No substantive opposing views were expressed to HedgeStreet with respect to these
amendments.

Should you have any questions regarding the above, please do not hesitate to contact
Stephanie Ford by telephone at (650) 638-3511 or by email at sford@hedgestreet.com.

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

ce: Tom Leahy — CFTC
Phil Colling - CFTC
Clarissa Manansala — HedgeStreet , Inc.

1825 S. Grant Street
‘Suite 500
San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

EXHIBIT A

Amendments to Rule 12.63 and Rule 12.78
(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.63 CURRENCY EXCHANGE USD/CHF BINARY HEDGELET
CONTRACTS

(a) - (e) [unchanged]

(f) PAYOUT CRITERION -— The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
USD/CHF Binary Hedgelet Contract, the Payout Criteria for the Contracts will be
set as follows:

(i) DAILY USD/CHF BINARY CONTRACTS 12 NOON
(ET) CLOSE and 3PM (ET) CLOSE

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0125.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0100.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0075.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout

Criterion of greater than X (rounded to the nearest 0.0025) — 0.0050.

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0025.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025).

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0025.

(8) Binary Hedgelet Contract 8: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0050.

1825 S. Grant Street
Sulte 500
San Mateo, CA 94402
Tel: 650.638.3500
www. hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

(9) Binary Hedgelet Contract 9: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0075.

(10) Binary Hedgelet Contract 10: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0100.

(11) Binary Hedgelet Contract 11: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) + 0.0125.

(12) In each case, “X” equals the last USD/CHF price or value
rounded to the nearest 0.0025 as reported by the Source Agency.

9 (ii) DAILY USD/CHF BINARY CONTRACTS 8 PM
ET) CLOSE

(1) - (13) [unchanged]

(14) In each case, ““X” equals the last USD/CHF price or value

rounded to the nearest 0.0025 as reported in-the spot USD/CHF foreign currency
ketat SPM -EF-on-the-previ ry by the Source Agency.

4) (iii) [except for renumeration, this rule is unchanged]

(g) - (0) [unchanged]
RULES 12.64 ~ 12.77 [unchanged]

RULE 12.78 CURRENCY EXCHANGE USD/CAD BINARY HEDGELET
CONTRACTS

(a) - (e) [unchanged]

(f) PAYOUT CRITERION — The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
USD/CAD Binary Hedgelet Contract, the Payout Criteria for the Contracts will be
set as follows:

(i) DAILY USD/CAD BINARY CONTRACTS 12 NOON
(ET) CLOSE and 3PM (ET) CLOSE

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than X (rounded to the nearest 0.0025) — 0.0125.

1825 S. Gront Street
Sulte 500
San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501