Ms. Jean A. Webb
June 10, 2005
Page 5 of 8

Thereafter, when a settlement price in the underlying futures contract occurs at, or passes
through, any exercise price, the Exchange shall add, on the next trading day, all eligible exercise
prices in the corresponding range. New options may be listed for trading up to an including the
termination of trading.

The Board may modify the provisions governing the establishment of exercise prices as it deems
appropriate.

CHAPTER 359A
Options on E-mini NASDAQ 100 Index® Futures

359A01.C. Minimum Fluctuations

The price of an option shall be quoted in index point. Each .01 index point shall represent $0.20.
The minimum fluctuation shall be 0.25 [9-05] index points (also known as one tick), equivalent
to $5[4]. 00 per contract. (F 4 ice-0f 0.025 index points $0-50_ak

parties to-the-trade-] A trade with a price equal to or Jess than 3.00 index points may also occur at
a price in multiples of .05 index points, $1.00.

359A01.E. Exercise Prices

The exercise prices shall be stated in terms of the E-Mini Nasdaq 100 Index futures contract
which is deliverable upon exercise of the option. The exercise prices shall be integers divisible
by [48] 25 without remainder, e.g., 2000, 2025[40], 2050[20], 2075[39], etc.


Ms. Jean A. Webb
June 10, 2005
Page 8 of 8

Thereafter, when a daily settlement price in the underlying futures contract occurs at, or passes
through, any exercise price, the Exchange shall list on the next trading day put and call options
with all eligible exercise prices in the above ranges.

The Board may modify the provisions governing the establishment of exercise prices as it deems
appropriate.


Ms. Jean A. Webb
June 10, 2005
Page 4 of 8

Text of Rule Amendments
(Additions are underlined, deletions are bracketed and overstruck.)

CHAPTER 357A
Options on NASDAQ 100 Index Futures

357A01.C. Minimum Fluctuations

The price of an option shall be quoted in index points. Each .01 index point shall represent
$1.00. The minimum fluctuation shall be 0.25 [65] index points (also know as one tick),

equivalent to $25.00 per contract. [Frad ¥y price of 025 index points ($250,
leo half tick)-wheth such trad: it in the Hquidation of positions f

F For noet-such tra iF P

both-partieste-the trade] A. ‘trade with a price equal to or less than 3.00 index points may also
occur at a price in multiples of .05 index points, $5.00.

357A01.E. Exercise Prices
[4-——Options inthe March Quarterly Cyele]

The exercise prices shall be stated in terms of the futures contract which is deliverable upon
exercise of the option. In all contract months, the exercise prices shall be an integer divisible by
25 [58] without remainder, e.g., 2000, 2025, 2050, [2400_]etc.

A referencing index shall be determined each quarter on the expiration day of the March
Quarterly futures. The referencing index shall equal the previous day's settlement price of the
lead month NASDAQ 100 Index futures contracts. The chosen referencing index will then be
used to calculate the index points for the [30%-and] 15% and 7.5% ranges for various contract
month options as specified below. The index points are rounded to the nearest integer.

[Atth toeftradine for the fourth " tract th in-the- March quartert:
5s S quai y

eyele;] For all eligible contract months, the Exchange shall list all eligible exercise prices in a
range of [39] 15 percent of the referencing index above and below the previous day's settlement
price of the underlying futures contract.

Thereafter, for all listed contract months [ tract th in the March-quarterly-cyele], when a
settlement price in the underlying futures contract occurs at, or passes through, any exercise
price, the Exchange shall add all eligible exercise prices on the next trading day.

When a contract month becomes the [second-nearest] nearest expiring contract month [##the
Mareh-quarterly cycle], the Exchange shall add exercise prices at an interval that is an integer
divisible by [49] 5 without remainder in a range of [45] 7.5 percent of the referencing index
above and below the previous day's settlement price of the underlying futures contract. If the
previous day's settlement price equals an eligible exercise price, then that exercise price shall be
listed also, if not previously listed.


Ms. Jean A. Webb
June 10, 2005
Page 6 of 8

At the commencement of option trading for E~Mini Nasdaq 100 option contracts the Exchange
shall list all eligible exercise prices in a range of 100 index points above and below the previous
day's settlement price of the E-Mini Nasdaq 100 Index futures contract.

When a contract month becomes the nearest expiring contract month, the Exchange shall add
exercise prices at an interval that is an integer divisible by 5 without remainder in a range of 100
index points above and below the previous day's settlement price of the underlying futures
contract. If the previous day's settlement price equals an eligible exercise price, then that
exercise price shall be listed also, if not previously listed.

Thereafter, when a daily settlement price in the underlying futures contract occurs at, or passes
through, any exercise price, the Exchange shall list on the next trading day put and call options
with all eligible exercise prices in the above ranges.

The Board may modify the provisions governing the establishment of exercise prices as it deems
appropriate.

Clean Copy

CHAPTER 357A
Options on NASDAQ 100 Index Futures

357A01.C. Minimum Fluctuations

The price of an option shall be quoted in index points. Each .01 index point shall represent
$1.00. The minimum fluctuation shall be 0.25 index points (also know as one tick), equivalent to
$25.00 per contract. A trade with a price equal to or less than 3.00 index points may also occur
at a price in multiples of .05 index points, $5.00.

357A01.E. Exercise Prices

The exercise prices shall be stated in terms of the futures contract which is deliverable upon
exercise of the option. In all contract months, the exercise prices shall be an integer divisible by
25 without remainder, e.g., 2000, 2025, 2050, etc.

A referencing index shall be determined each quarter on the expiration day of the March
Quarterly futures. The referencing index shall equal the previous day's settlement price of the
lead month NASDAQ 100 Index futures contracts. The chosen referencing index will then be
used to calculate the index points for the 15% and 7.5% ranges for various contract month
options as specified below. The index points are rounded to the nearest integer.

For all eligible contract months, the Exchange shall list all eligible exercise prices in a range of
15_percent of the referencing index above and below the previous day's settlement price of the
underlying futures contract.


RECEIVED

mac cmee

nn: - Chicago Mercantile Exchange
2S JUN 10 PH 12: 20
— 20 South Wacker Drive 312/930.1000 tel
OFC. OF THE SECRETARIAT Chicago, IL 60606-7499 312/466.4410 fax

www.cme.com,

June 10, 2005

Ms. Jean A. Webb

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

RE: Section 5c(c)(1), Part 40.6 - Amendments to Chapters 357A and 359A,
Options on Nasdaq 100 and E-Mini Nasdaq 100 futures contracts.
CME Submission# 05-64.

Dear Ms. Webb:

Chicago Mercantile Exchange Inc. (“CME” or “Exchange”) hereby notifies the
Commission of amendments to the options on Nasdaq 100 and E-Mini Nasdaq 100 futures
contracts.

The Exchange certifies that this action neither violates nor is inconsistent with any
provision of the Commodity Exchange Act or of the rules thereunder.

Customer demand has prompted the Exchange to amend the minimum tick fluctuations
and exercise price intervals for both the Nasdaq 100 and E-Mini Nasdaq 100 options contracts.
The current minimum tick fluctuation for the Nasdaq 100 and the E-Mini Nasdaq 100 contracts
is 0.05. The minimum fluctuation for both options contracts will be changed to a variable tick
similar to the one used for the S&P contracts. Any premium greater than $3.00 will tick in 0.25
increments. Any premium less than or equal to $3.00 will tick in 0.05 increments.

In addition, the strike listing rules will also be amended. Currently, the Nasdaq 100
options contract strike listing rules are based on a 30% reference index with 50 point strike
intervals. Ten point strike intervals are added in the two nearest quarterlies based upon a 15%
teference index. The strike listing rules for the Nasdaq 100 options contract will now be based
on a 15% reference index with 25 index point intervals. Five point strike intervals will be added
in the lead contract month. The E-Mini Nasdaq 100 options contract strike listing rules currently
allow for a 100 index point range with 10 index point intervals. The amended listing rules for E-


Ms. Jean A. Webb
June 10, 2005
Page 7 of 8

Thereafter, for all listed contract months, when a settlement price in the underlying futures
contract occurs at, or passes through, any exercise price, the Exchange shall add all eligible
exercise prices on the next trading day.

When a contract month becomes the nearest expiring contract month, the Exchange shall add
exercise prices at an interval that is an integer divisible by 5 without remainder in a range of 7.5
percent of the referencing index above and below the previous day's settlement price of the
underlying futures contract. If the previous day's settlement price equals an eligible exercise
price, then that exercise price shall be listed also, if not previously listed.

Thereafter, when a settlement price in the underlying futures contract occurs at, or passes
through, any exercise price, the Exchange shall add, on the next trading day, all eligible exercise
prices in the corresponding range. New options may be listed for trading up to an including the
termination of trading.

The Board may modify the provisions governing the establishment of exercise prices as it deems
appropriate.

CHAPTER 359A
Options on E-mini NASDAQ 100 Index® Futures

359A01.C. Minimum Fluctuations

The price of an option shall be quoted in index point. Each .01 index point shall represent $0.20.
The minimum fluctuation shall be 0.25 index points (also known as one tick), equivalent to $5.00
per contract. A trade with a price equal to or less than 3.00 index points may also occur at a
price in multiples of .05 index points, $1.00.

359A01.E. Exercise Prices

The exercise prices shall be stated in terms of the E-Mini Nasdaq 100 Index futures contract
which is deliverable upon exercise of the option. The exercise prices shall be integers divisible
by 25 without remainder, e.g., 2000, 2025, 2050, 2075, etc.

At the commencement of option trading for E-Mini Nasdaq 100 option contracts the Exchange
shall list all eligible exercise prices in a range of 100 index points above and below the previous
day's settlement price of the E-Mini Nasdaq 100 Index futures contract.

When a contract month becomes the nearest expiring contract month, the Exchange shall add
exercise prices at an interval that is an integer divisible by 5 without remainder in a range of 100
index points above and below the previous day's settlement price of the underlying futures
contract. If the previous day's settlement price equals an eligible exercise price, then that
exercise price shall be listed also, if not previously listed.


Ms. Jean A. Webb
June 10, 2005
Page 2 of 8

Mini Nasdaq 100 options retain the 100 index point range but increase the interval from 10 to 25.
In addition, 5 point strike intervals will be added in the lead contract month.

The variable tick table will be implemented on July 17, 2005 for a July 18, 2005 trade
date. The amendments to the strike listing rules will be phased in as each currently listed
contract expires. As of June 10, 2005, the following contracts are currently listed for trading and
will retain original strike listing rules:

+ Nasdaq 100 Options — June 2005, July 2005, August 2005, September 2005, December
2005
¢ E-Mini 100 Options - June 2005, July 2005, August 2005, September 2005

The June 2005 options contracts will expire on June 17, 2005. There will be a one month delay
in listing the Nasdaq 100 March 2006 options contract in order to give customers enough time to
implement the strike listing rule changes. In lieu of adding the March 2006 contract on June 19,
2005, the contract will be listed for trading on July 17, 2005. All other contracts months will
follow their normal listing schedule. The list below details the strike listing rule change
implementation process.

+ Nasdaq 100 Options contract roll out
- July 17, 2005 [March 2006 — amended rules]
- July 17, 2005 [October 2005 — original rules]
- August 21, 2005 [November 2005 — original rules]
- September 18,2005 [June 2006 — amended rules}
- All listed contracts following the October 2005 expiration will use the amended
strike listing rules.

+ E-Mini Nasdaq 100 Options contract roll out
- June 19, 2005 [December 2005 — original rules]

- July 17, 2005 [October 2005 — original rules]

- August 21, 2005 [November 2005 — original rules]

- September 18,2005 [March 2006 — amended rules]

- All listed contracts following the October 2005 expiration will use the amended
strike listing rules.

The table below illustrates the changes for each options contract with the amended rules
following. Additions are underlined and deletions are bracketed and struck out.


Ms. Jean A. Webb

‘June 10, 2005
Page 3 of 8
Ticks ‘Amended*
0.25 for premiums >
$3.00; 0.05 for
premiums <= $3.00
0.25 for premiums >
$3.00; 0.05 for
premiums <= $3.00
Strike Listings As Ame

100 point range @ 25

100 point range @ 10 point intervals; lead
point intervals month add in 5 point
intervals

30% reference index @

| 50 point intervals; 15%

reference index @ 10
point intervals in 2
nearest quarterlies

15% reference index @
25 point intervals; lead
month add in 5 point
intervals

* Effective for July 18, 2005 trade date.

If you require any additional information regarding this action, please do not hesitate to
contact Ms. Ariel Hantin, Senior Research Analyst at 312-559-4951 or via e-mail at
ahantin@cme.com. Please reference our CME Submission #05-64 on all future correspondence
regarding this notification.

Sincerely,

SL

John W. Labuszewski, Director
Research & Product Development

ce: Mr. Thomas M. Leahy and Mr. Steven B. Benton
CFTC Division of Market Oversight, Product Review & Analysis Section