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ee World Financial Center
OFC. OF THE SECRETARIAT One North End Avenue

New York, New York 10282

BY ELECTRONIC TRANSMISSION

05-27
June 9, 2005

Ms. Jean A. Webb

Secretary of the Commission

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21* Street, NW

Washington, DC 20581

Re: Amendments to Rule 4.19 -
Submission Pursuant to Section 5c(c)(1) of the Act and Regulation 40.6

Dear Ms. Webb:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended, and
Commission Regulation 40.6, the Board of Trade of the City of New York, Inc. (“Exchange”)
submits, by written certification, amendments to Rule 4.19, attached as Exhibit A.

Currently, Rule 4.19 allows a floor broker to take the opposite of his customer’s order, if
he has the prior written consent of his customer and the order pertains to Cotton, Pulp, Index or
Financial contracts. The amendment adds Cocoa to the list of commodity contracts for which a
floor broker may take the opposite side of his customer’s order.

The amendments were adopted at the request of the Cocoa Contract Committee in
response to competitive forces that have eroded the Exchange’s volume and open interest in the
Cocoa contract. The purpose is to increase liquidity and the opportunity for customers to get
their orders executed. Out of all of the trading rings at the Exchange, the Cocoa ring has the
smallest percentage of local traders, i.e. those who trade solely for their own account. By
allowing floor brokers to take the opposite side of their customers’ orders, more people may
participate.

The Exchange certifies that the amendments comply with the requirements of the
Commodity Exchange Act and the rules and regulations promulgated thereunder.


2-

The amendments were adopted by the Exchange’s Board of Governors on June 8, 2005.
The amendments will become effective on June 20, 2005. No substantive opposing views were
expressed by members or others with respect to the amendments.

If you have any questions or need further information, please contact me at

jfassler@nybot.com or 212-748-4084.

Sincerely,

Jill S. Fassler
Vice President
Associate General Counsel

cc: Riva Adriance
CFTC, Division of Market Oversight
Allen Cooper
CFTC, New York Regional Office


(In the text below additions are underlined and deletions are bracketed and lined out.)

Rule 4.19. Cross Trades

(a) Subject to the conditions set forth in this Rule, a Floor Brokér who has in hand at the same time
both buying and selling or granting Exchange orders of different Principals for the same Commodity
Contract in the same delivery month or Exchange Option series may execute such orders for and directly
between such Principals at the market price; provided, however, that:

(i) with respect to Cocoa, Cotton No. 2, Pulp, Index and Financial Futures and Options Contracts, if
any one (1) of the accounts listed below in (A) through (D) is opposite a Customer’s order, the Floor
Broker has the prior written consent of such Customer to cross his order opposite any one (1) of the
following accounts:

(A) the Floor Broker’s own account or an account in which the Floor Broker has a direct or
indirect interest;

(B) an account of another Person for which buying and/or selling orders can be placed or
originated, or for which Transactions can be executed, by such Floor Broker without the prior
specific consent of the account owner;

(C) the account of an Associated Broker or an account controlled by such Associated Broker; or

(D) the account of any Firm of which the Floor Broker is a partner, officer, or employee or any
other affiliate of such Firm, or the account of any partner, officer or employee of such Firm or any
other affiliate of such Firm; for purposes of this Rule, the term "affiliate" means any Firm or
individual which controls, is controlled by, or is under common control with, another Firm or
individual; and for purposes of this Rule, the term "control" means the power to direct or cause the
direction of the management or policies of a Firm or individual, whether through ownership of
securities, by contract, or otherwise.

(ii) with respect to [Geeea;] Coffee “C”, Ethanol, Sugar No. 11 and Sugar No. 14 Futures and
Options Contracts, Transactions described in paragraph (a) of this Rule may be executed as long as
neither of the orders is for:

(A) the account of a Floor Broker present on the Floor of the Exchange, or an account controlled
by such Floor Broker;

(B) the Floor Broker’s own account or an account in which the Floor Broker has a direct or
indirect interest;

(C) an account of another Person for which buying and/or selling orders can be placed or
originated, or for which Transactions can be executed, by such Floor Broker without the prior
specific consent of the account owner;

(D) the account of an Associated Broker or an account controlled by such Associated Broker; or

(E) the account of any Firm of which the Floor Broker is a partner, officer or employee of such
Firm or any other affiliate of such Firm; for purposes of this Rule, the term “affiliate” means any
Firm or individual which controls, is controlled by, or is under common control with, another Firm
or individual; and for purposes of this Rule, the term "control" means the power to direct or cause
the direction of the management or policies of a Firm or individual, whether through ownership of
securities, by contract, or otherwise.

{REMAINDER OF RULE UNCHANGED]
EXHIBIT A