(vi) such other information as may be requested by the Exchange.

(i) Review of Application for Exemption. The President of the Exchange or his designee shall notify an applicant
whether an exemption has been granted (or may continue, in the event that the applicant's request is amended) and
of any limitations placed thereon, within ten (10) business days of receipt of the written submission (or amended
submission, as the case may be) of the applicant and such supplemental information as the Exchange may request,
or within such additional time as the Exchange may require to evaluate such filings.

(j) Duration of Exemption. An exemption from a position limit will remain in full force and effect until (i) the applicant
requests a withdrawal; or (ii) the Exchange revokes, modifies or places further limitations thereon. Notwithstanding
the foregoing, the President or his designee may review at any time exemptions granted under this Rule and may
modify, revoke, or limit such exemptions as he so determines. Nothing in this Rule shall in any way limit (i) the
authority of the Exchange to take emergency action; or (ii) the authority of the Board, or upon request and delegation
by the Board, the Control Committee to review at any time the position owned or controlled by any person and to
direct that a position be reduced to the position limit prescribed in this Rule.


An application for an exemption shall include the following:

(i) an estimate of the size of the position, by contract, intended to be established on the Exchange, for which the
exemption is requested;

(ii) information, including a description of the size and type of physical commitments corresponding to the contracts
for which the exemption is sought, which will demonstrate that the proposed transactions are bona fide hedges;

(iii) a representation that the intended transactions will be bona fide hedges;

(iv) a representation that the applicant immediately will report to the Exchange any material changes in
circumstances or information pro- vided in the application; and

(v) such further information as the Exchange may request.

(2) Spread and Arbitrage Positions. The position limits specified in section (b) of this Rule shall not apply to spread
and arbitrage positions for which an exemption has been granted (and not revoked) by the Exchange.

To be eligible for an exemption, an applicant must submit a written request to the Exchange which includes the
following:

(i) an estimate of the size of the position, by contract, intended to be established on the Exchange, for which the
exemption is requested;

(ii) a description of the size and type of the proposed transactions;
(iii) a representation that all of the intended transactions will be spreads or arbitrages;

{iv) a orderly manner, will not be initiated or liquidated in an orderly manner, will not be initiated or liquidated in a
manner calculated to cause unreasonable price fluctuations or unwarranted price changes, and will not be used in
an attempt to violate or avoid Exchange Rules, or otherwise impair the good name or dignity of the Exchange;

(v) a representation that the applicant immediately will report to the Exchange with any material change in
circumstances or information provided in the application; and

(vi) such further information as the Exchange may request.

(3) Commodity Swap Transactions. The position limits specified in section (b) of this Rule, other than the spot month
limit, shall not apply to positions intended to reduce exposure resulting from commodity swap transactions which
meet all of the criteria enunciated by the CFTC in the Policy Statement Concerning Swap Transactions, 54 Fed. Reg.
30694 (July 21, 1989), and as it may be amended or interpreted by the Commission, for which an exemption has
been granted, and not revoked by, the Exchange.

To be eligible for an exemption for these transactions, the applicant must submit a written request to the Exchange
which shall include:

(i) an estimate of the size of the position, by commodity, intended to be established on the Exchange, for which the
exemption is requested;

(ii) a complete description of the underlying swap exposure;

(iii) a representation that the swap transactions satisfy the criteria outlined in the Policy Statement, as such may be
amended or interpreted by the Commission;

(iv) a representation that the positions which are the subject of the exemption will be traded in an orderly manner, will
not be initiated or liquidated in a manner calculated to cause unreasonable price fluctuations or unwarranted price
changes, and will not be used in an attempt to violate or avoid Exchange Rules, or otherwise impair the good name
or dignity of the Exchange;

(v) a representation that the applicant immediately will report to the Exchange any material change in circumstances
or information provided in the application; and


(FOR DISTRIBUTION AFTER THE CLOSE OF BUSINESS)

Notice No. 05-528
November 17, 2005

TO: All Exchange Members, Member Firms and Clearing Members
FROM: James E. Newsome, President

RE: COMEX Spot Month Copper Position Limit Reduction

COMEX warehouse stocks for copper as of the close of business November 14, 2005, were 295
contract equivalents. Consequently, pursuant to Exchange Rule 104.47(b), the Control
Committee has determined to reduce the copper futures spot month position limit from 500
contracts to 250 contracts, effective on the close of business Tuesday, November 29, 2005,
beginning with the December 2005 copper futures contract.

Should you have any questions, please contact Anthony V. Densieski, Senior Director, Market
Surveillance, at (212) 299-2881, Nicholas Galati, Director, Market Surveillance, at (212) 299-
2920, or Bonnie Yurga, Senior Manager, Market Surveillance, at (212) 299-2879.



November 17, 2005
Via E-Mail

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: Rule Certification. NYMEX Submission 05.206: Notification of
Copper Spot Month Position Limit Reduction [Rule 104.47(b)}.

Dear Ms. Jean Webb:

The New York Mercantile Exchange ("NYMEX" or the "Exchange") is notifying the
Commodity Futures Trading Commission (““CFTC” or “Commission”) of the COMEX Division
Copper Futures contract spot month position limit change to 250 contracts.

COMEX warehouse stocks for copper, as of the close of business November 14, 2005,
were 295 contract equivalents. Consequently, in accordance with procedures described in
Exchange Rule 104.47(b), the Control Committee has determined to reduce the Copper Futures
spot month position limit from its present level of 500 contracts to 250 contracts effective the
close of business Tuesday, November 29, 2005. Exchange Notice to Members No. 05-528 dated
November 17, 2005, to be distributed after the close of the Copper market later today, is
attached. Pursuant to Section Sc(c) of the Commodity Exchange Act (“Act”) and CFTC Rule
40.6, the Exchange hereby certifies that the attached notification complies with the Act,
including regulations under the Act.

Should you have any questions concerning the above, please contact Thomas LaSala,
Senior Vice President, Compliance and Risk Management, at (212) 299-2897, or the undersigned
at (212) 299-2207.

Very truly yours,

Nancy M. Minett
Vice President
Compliance Department

ce: Thomas LaSala
Brian Regan



COMEX Rule 104.47 Position Limits

104.47 Position Limits

(a) Aggregation. The position limits established by this Rule and the position accountability levels prescribed
pursuant to Rule 104.48 ("Position Accountability") shail apply to all positions held by any person, including positions
in any account(s) in which such person has a financial interest of 10% or more and in any accounts) for which such
person controls trading (directly or indirectly, by power of attorney or otherwise); and, in the case of positions held by
two or more persons acting pursuant to an express or implied agreement or understanding, the same as if all of the
positions were held by a single person. For purposes of this Rule, the term "person" shall mean any individual or
entity.

(b) Applicable Limits. The maximum number of futures contracts, options on such futures contracts, or any
combination thereof (collectively referred to as a position”) which any person may own or control is as follows:

Commodity Spot Month Net Limit* Any One Month/All Months Net Futures Equivalent Limit
Gold 3,000 Subject to Position Accountability
Silver 1,500 Subject to Position Accountability
Aluminum 750°* Subject to Position Accountability
Copper 3,000°** Subject to Position Accountability

*Effective as of the close of business on the second last business day of the calendar month preceding the delivery
month.

**To the extent that for a period of three consecutive trading days, there is either: (1) a backwardation of price
between the first month and next most active month (first month's price above nearest active month’s price); or (2)
registered stocks which fall below 5,000 contract equivalents, the limits in place for the first month shall be reduced
to 350 contracts at the close of business three trading days later unless decided otherwise by the Control!
Committee.

“If at any time registered stocks fall below 20,000 contract equivalents, the limits in place may be reduced below
3,000 contracts at the discretion of the Control Committee at the close of business three trading days later unless
decided otherwise by the Control Committee.

(c) Computation of Positions. For purposes of this Rule,

(1) option positions shall be computed as futures equivalents. The futures equivalent of an option position shall be
obtained by multiplying the preceding day's delta factor for the relevant strike price of an option, as published by the
Exchange, by the number of contracts held at that strike price.

(2) a long future, a long call option and a short put option are on the same side of the market. Similarly a short future,
a short call option and a long put option are on the same side of the market.

(3) in calculating a spot month position, the number of contracts against which delivery notices have been stopped
(issued) during a delivery month minus the number of contracts against which delivery notices have been issued
(stopped) shall be added to a long (short) spot month futures position.

(d) Enforcement of Limits.

(1) General. No member or member firm may maintain, for itself or for any customer, any position which is, or which
when aggregated in accordance with section (a) of this Rule is, in excess of the applicable limit for that commodity,
unless (A) a request for an exemption has been filed with the Exchange, in the case of non-spot month bona fide
hedging, spread and arbitrage positions, or (B) such position have been exempted from the applicable limit. If any
position exceeds the limit and has not been exempted (or is not the subject of a request for a bona fide hedge,
spread or arbitrage exemption in non-spot month contract), the member or member firm maintaining or carrying the
account(s) in which the position is held immediately shail take such steps as are necessary to reduce the position
below the applicable limit.

(2) Alternative Delta Factors. If a position exceeds position limits when evaluated using the previous day's delta
factors, but does not exceed the limit using the delta factors as of that day's close of trading, the position shall not be
deemed to violate the applicable position limit.


(e) Accounts Maintained at Multiple Firms. In the event that the Exchange learns that any person maintains positions
in accounts at more than one member or member firm such that the aggregate position in all the accounts exceeds
the applicable position limit, the Exchange may notify the members or member firms maintaining or carrying such
accounts of the total positions of such accounts. The Exchange may instruct each such member and member firm to
reduce the positions in such accounts within 24 hours of receipt of such instructions, proportionately or otherwise, so
that the aggregate positions in the accounts at all such members and member firms does not exceed the position
limit, unless during such 24-hour period a request for an exemption from the position limit is made and granted. A
member or member firm receiving such instructions immediately shall take such steps as may be necessary to
liquidate such number of contracts as shall be determined by the Exchange in order to cause the aggregate
positions of such accounts at such member or member firms to comply with the applicable position limit.
Notwithstanding the foregoing, the members and member firms may reduce the positions of such accounts by a
different number of contracts than that required by the Exchange so long as after all reductions have been
completed at all member and member firms carrying such accounts, the positions at all such members or member
firms shall comply with the applicable position limits.

(f) Failure to Reduce Positions. In addition to any other powers, remedies and sanctions contained in the By-laws
and Rules, the Board, or upon request and delegation by the Board, the Control Committee, may require every
member or member firm that maintains an account holding a position in excess of applicable position limits then in
effect, to take immediate steps to reduce positions in such accounts to levels that do not violate such position limits
and to take such other actions, within such periods and upon such terms, with respect to such accounts as the
Board or the Control Committee may deem necessary or desirable.

(g) Submission of Request for Exemption.

(1) Source of Submission. A request for an exemption specified in section (h) of this Rule may be submitted either by
the member or member firm carrying an account for which an exemption is sought, by a beneficial owner of such
account, or by a person vested with discretion to trade the account, unless otherwise provided in this Rule or
permitted by the Exchange.

(2) Deadline. A request for an exemption for bona fide hedging, spread and arbitrage positions must be filed within
five (5) business days after a position exceeds the applicable position limit, unless the applicant is seeking an
exemption for spot month positions in which case, the request must be filed and granted before the position may be
increased above the applicable limit, provided, however, that the President or his designee may in special
circumstances authorize the late filing of any exemption report. A request for any other type of exemption permitted
under this Rule must be filed and granted before the position may be increased above the applicable limit.

(3) Form. A request shall be submitted in such form as the Exchange may prescribe and shall contain all information
the Exchange may request in order to be considered complete.

(4) Identification of Accounts. If a member or member firm is submitting a request on behalf of the account holder or
controller, the application must indicate whether the account holder or controller maintains positions for which the
exemption is sought with any other member or member firm and/or has made a previous or contemporaneous
request for an exemption through another member or member firm. If the request is submitted by the account holder
or controller, the application shall identify each account (and the firm at which it is cleared) for which the exemption is
sought and shall disclose whether a previous or contemporaneous request for an exemption has been made for the
account.

(5) Modifications and Supplements. If any material terms of an application for an exemption change while the
Exchange is reviewing the application or during the period in which the exemption is effective, the applicant shall be
responsible for the submission of corrective or updated information. An applicant also must provide such additional
information-as the Exchange may request to evaluate the application for an exemption or to determine the scope or
duration of an exemption once granted. Should the applicant fail to submit such information to the Exchange, or if
any representations contained in the application are materially false, the applicant may not rely upon the exemption
granted, and the Exchange may revoke the exemption or deny the application, as the case may be.

(h) Exemptions.
(1) Bona Fide Hedging Transactions. The position limits specified in section (b) of this Rule shall not apply to bona

fide hedging positions, as defined in CFTC Regulation 1.3(z)(1), for which an exemption has been granted (and not
revoked) by the Exchange.