03/15/2006 13:51 FAX 312 424 8529 OneChicago

(©)

@

ONECHICAGO, LLC

005

OneChicago meets the provisions of Part 38 of CFTC Regulations, as
applicable as described in all material respects in submissions to, and
filings with the CFTC and its staff (and amendments and supplements
thereto) and in explanation, representations, and presentations (both
written and oral, formal and informal) to the CFTC and its staff (and
amendments, supplements, and clarifications thereto), including, but not
limited to, as described in OneChicago’s rules approved by the CFTC and
amendments to those rules filed with the CFTC and certified by
OneChicago.

OneChicago will perform its three key functions as a contract market and
self-regulatory organization — trade execution, clearing and settlement
processing, and regulatory services — using the same third-party services
providers previously identified to the CFTC and its staff,! which provide
services in a manner using methods that conform in all material respects to
descriptions in submission to and filings with the CFTC and its staff (and
amendments and supplements thereto) and in explanation, representations,
and presentations (both written and oral, formal and informal) to the
CFTC and its staff (and amendments, supplements, and clarifications
thereto), including, but not limited to, as described in OneChicago’s rules
approved by the CFTC and amendments to those rules filed with the
CFTC and certified by OneChicago.

Interactive Brokers Group, LLC
By.

Name.

Its:

Date.

.: The CBOE continues to perform trade matching and execution pursuant to its Matching Services

Agreement with OneChicago (dated March 1, 2002): The Options Clearing Corporation continues to
perform clearing and settlement processing pursuant to the Securities Futures Agreement for Clearing and
Settlement Services (dated April 1, 2002). The CME continues to perform regulatory services pursuant to
its Regulatory Services Agreement with OneChicago (dated April 2, 2002), and continues to provide
clearing services pursuant to its Clearing Services Agreement with OneChicago (dated April 1, 2002), and
continues to provide order routing and order management services pursuant to its Connectivity Services
Agreement with OneChicago (date October 16, 2003).


"03/15/2006 13:50 FAX 312 424 8529

©)

@

ONECHICAGO, LLC

Chicago Mercantile Exchange Inc.

By.

Name.
~ Its:

Date:

OneChicago 004

OneChicago meets the provisions of Part 38 of CFTC Regulations, as
applicable as described in all material respects in submissions to, and
filings with the CFTC and its staff (and amendments and supplements
thereto) and in explanation, representations, and presentations (both
written and oral, formal and informal) to the CFTC and its staff (and
amendments, supplements, and clarifications thereto), including, but not
limited to, as described in OneChicago’s rules approved by the CFTC and
amendments to those rules filed with the CFTC and certified by
OneChicago; and

OneChicago will perform its three key functions as a contract market and
self-regulatory organization — trade execution, clearing and settlement
processing, and regulatory services — using the same third-party service
providers previously identified to the CFTC and its staff,’ which provide
services in a manner using methods that conform in al] material respects to
descriptions in submissions to and filings with the CFTC and its staff (and
amendments and supplements thereto) and in explanation, representations,
and presentations (both written and oral, formal and informal) to the
CFTC and its staff (and amendments, supplements, and clarifications
thereto), including, but not limited to, as described in OneChicago’s rules
approved by the CFTC and amendments to those rules filed with the
CFIC and certified by OneChicago.

CBOE, LLC
By.

Name

Its:

Date

Interactive Rrokers 1p, LLC
By. A } Me tol
Name_PAViD m. BATTAN
Its:__ Vite PRES WENT
Date__3- 14-06

"Bg: The CBOE continues to perform trade matching and execution pursuant to its Matching Services
Agreement with OneChicago (dated March 1, 2002). The Options Clearing Corporation continues to
perform clearing and settlement processing services pursuant to the Securities Futures Agreement for
Clearing and Settlement Services (dated April 1, 2002), The CME continues to perform regulatory services
pursuant to its Regulatory Services Agreement with OneChicago (dated April 2, 2002), and continues to
provide clearing services pursuant to its Clearing Services Agreement with OneChicago (dated April 1,
2002), and continues to provide order routing and order management services pursuant to its Connectivity
Services Agreement with OneChicago (date October 16, 2003).



@oos

03/15/2006 13:51 FAX 312 424 8529 OneChicago
¥

4
H
;
5
a
3
i
i
:
3
i
2
i
;
4
3
a
i
i
}
:

(c) OneChicago meets the provisions of Part 38 of CFTC Regulations, as
applicable as described in all material respects in submissions to, and
filings with the CFTC and its staff (and amendments and supplements
thereto) and in explanation, representations, and presentations (both
written and oral, formal and informal) to the CFTC and its staff (and
amendments, supplements, and clarifications thereto), including, but not
limited to, as described in OneChicago’s rules approved by the CFTC and
amendments to those rules filed with the CFTC and certified by
OneChicago; and

(a) — OneChicago will perform its three key functions as a contract market and
self-regulatory organization — trade execution, clearing and settlement
processing, and regulatory services — using the same third-party service
providers previously identified to the CFTC and its staff,’ which provide
services in a manner using methods that conform in all material respects to
descriptions in submissions to and filings with the CFTC and its staff (and
amendments and supplements thereto) and in explanation, representations,
and presentations (both written and oral, formal and informal) to the
CFTC and its staff (and amendments, supplements, and clarifications
thereto), including, but not limited to, as described in OneChicago’s rules
approved by the CFTC and amendments to those rules filed with the
CFTC and certified by OneChicago.

ONECHICAGO, LLC CBOE, LLC
By.

Name.

Its:

Date.

Interactive Brokers Group, LLC
By.

Name.

Its:

Date.

a Nat SRE RHE OER NES RDN

Agreement with OneChicago (dated March 1, 2002). The Options Clearing Corporation continues to
perform clearing and settlement processing services pursuant to the Securities Futures Agreement for
Clearing and Settlement Services (dated April 1, 2002). The CME continues to perform regulatory services
pursuant to its Regulatory Services Agreement with OneChicago (dated April 2, 2002), and continues to
provide clearing services pursuant to its Clearing Services Agreement with OneChicago (dated April J,
2002), and continues to provide order routing and order management services pursuant to its Connectivity
Services Agreement with OneChicago (date October 16, 2003).

i
4 S
j 'E.g.: The CBOE continues to perform trade matching and execution pursuant to its Matching Services


03/15/2006 13:48 FAX 312 424 8529 OneChicago

oor

OneChicago x

By Facsimile and FedEx

Ms. Jean A. Webb

Secretary of the Commission
Office of the Secretariat i
Commodity Futures Trading Commission E

CERTIFICATION PURSUANT TO CFTC RULE 38.5(d)

March 14, 2006

1155 21" Street, NW BE co
Washington, DC 20581

Re: Certification Pursuant to CFTC Rule 38.5(d) By Owners of OneChicago, LLC

Dear Ms. Webb,

Enclosed please find a Certification Pursuant to Rule 38.5(d) of the Commodity Futures
Trading Commission (“CFTC”) filed by OneChicago, LLC.

Please contact me at (312) 424-8520 if you have any questions concerning the enclosed

Certification.

cc:

141 West Jackson Blvd
Suite 2240

Chicago, illinois 60604
312.424.8500 tef
312.424.8529 fax
www onechicago.com

Sincerely,

Martin Doyle ol
President

Richard A. Shilts
Director, Division of Market Oversight

Riva Adriance
Chief, Market Review Branch,
Division of Market Oversight


03/15/2006 13:49 FAX 312 424 8529 OneChicago Qooz

CERTIFICATION PURSUANT TO RULE 38.5(d)
OF THE
COMMODITY FUTURES TRADING COMMISSION

WHEREAS, on or about August 3, 2001, OneChicago, LLC (“OneChicago” or the
“Company”) was formed as a Delaware limited liability company, with the following
partners: Chicago Mercantile Exchange, Inc. and Chicago Board Options Exchange
which each owned 41.625%, and others; and

WHEREAS, on or about June 11, 2002, the Commodity Futures Trading Commission
(the “CFTC”) designated OneChicago as a contract market pursuant to Sections 5 and 6
of the Commodity Exchange Act (the “Act”), 7 U.S.C. §§ 7 and 8, subject to the terms
and conditions set forth in the Order of Conditional Designation. And on November 7,
2002, the CFTC removed the conditions placed on OneChicago’s designation as a contact
market and issued a Final Order of Designation pursuant to Sections 5 and 6 of the act, 7
U.S.C. §§ 7 and 8; and

WHEREAS, on or about March 14, 2006, OneChicago received an equity investment
from Interactive Brokers Group, LLC (“IBG”). This transaction resulted in IBG owning
40% of the Company, and CBOE and CME each owning 24.01%;

NOW THEREFORE, because a change in ownership in OneChicago has occurred,
pursuant to CFTC Regulation 38.5 (d), OneChicago hereby certifies as follows:

(a) OneChicago meets all of the requirements set forth in Section 5 (b)
(Criteria for Contract Market Designation) of the Act, as described in all
material respects in submissions to, and filings with, the CFTC and its
staff (and amendments and supplements thereto) and in explanations,
representations, and presentations (both written and oral, formal and
informal) to the CFTC and its staff (and amendments, supplements, and
clarifications thereto), including, but not limited to, as described in
OneChicago’s rules approved by the CFTC and amendments to those rules
filed with the CFTC and certified by OneChicago;

(b) OneChicago meets all of the requirements set forth in Section 5(d) (Core
Principles for Contract Markets) of the Act, as described in all material
respects in submissions to, and filings with the CFTC and its staff (and
amendments and supplements thereto) and in explanation, representations,
and presentations (both written and oral, formal and informal) to the
CFTC and its staff (and amendments, supplements, and clarifications
thereto), including, but not limited to, as described in OneChicago’s rules
approved by the CFTC and amendments to those rules filed with the
CFTC and certified by OneChicago;


"03/15/2006 13:49 FAX 312 424 8529 OneChicago

(c)

@

@oo03

OneChicago meets the provisions of Part 38 of CFTC Regulations, as
applicable as described in all material respects in submissions to, and
filings with the CFTC and its staff (and amendments and supplements
thereto) and in explanation, representations, and presentations (both
written and oral, formal and informal) to the CFTC and its staff (and
amendments, supplements, and clarifications thereto), including, but not
limited to, as described in OneChicago’s rules approved by the CFTC and
amendments to those rules filed with the CFTC and certified by
OneChicago; and

OneChicago will perform its three key functions as a contract market and
self-regulatory organization — trade execution, clearing and settlement
processing, and regulatory services — using the same third-party service
providers previously identified to the CFTC and its staff,’ which provide
services in a manner using methods that conform in all material respects to
descriptions in submissions to and filings with the CFTC and its staff (and
amendments and supplements thereto) and in explanation, representations,
and presentations (both written and oral, formal and informal) to the

CFTC and its staff (and amendments, supplements, and clarifications
thereto), including, but not limited to, as described in OneChicago’s rules
approved by the CFTC and amendments to those rules filed with the
CFTC and certified by OneChicago.

e/a Le CBOE, LLC
By. By.
Name_/?4; LE Name.

Its: Eresidtst Its:

Date: 7Aarek 14, daeG Date.

Chicago Mercantile Exchange Inc. Interactive Brokers Group, LLC
By. By.

Name Name.

Its: Its:

Date: Date.

’B.g.: The CBOE continues to perform trade matching and execution pursuant to its Matching Services
Agreement with OneChicago (dated March 1, 2002). The Options Clearing Corporation continues to
perform clearing and settlement processing services pursuant to the Securities Futures Agreement for
Clearing and Settlement Services (dated April 1, 2002). The CME continues to perform regulatory services
pursuant to its Regulatory Services Agreement with OneChicago (dated April 2, 2002), and continues to
provide clearing services pursuant to its Clearing Services Agreement with OneChicago (dated April 1,
2002), and continues to provide order routing and order management services pursuant to its Connectivity
Services Agreement with OneChicago (date October 16, 2003).