Executive Summary

To achieve greater market
integrity through an enhanced
audit trail, the Philadelphia Board
of Trade (“PBOT”) requires each
PBOT member or member
organization to designate one
person—known as an
“Authorized Trader Contact”—as
the firm’s contact, who is
tesponsible for all business
conducted by or through the

member on PBOT. In addition,
to further enhance its audit trail,
PBOT requires each member to
identify the person submitting
each order, quote, or block trade
by attaching a unique identifier,
known as a Trader ID, at the time
of submission.

This Notice describes how
members register their
Authorized Trader Contacts, the
duties and responsibilities of
those contacts, the procedures for
de-registering or transferring of
those contacts, as well as the use
of Trader IDs,

Please direct any questions
concerning this Notice to Tom.
Young, PBOT Market
Surveillance — Special
Investigator, at (215) 496-1555,
or Bob Kreszswick, Director,
Membership Services, at (215)
496-6430,

Registration

According to PBOT rules, an
“Authorized Trader Contact” is
an employee or other person
associated with a member or
member organization
(collectively “members”) that is
tegistered with the PBOT and
responsible for all orders, quotes,
and block trades submitted by or
through the members’ trading

PBOT Notice to Members 02-2006

Notice to Members 02-2006

mnemonic, known as a Member
D!

To register an Authorized Trader
Contact, a member must
complete and submit PBOT’s
“Authorized Trader Contact
Registration Form.”” In addition,
each member is responsible for
ensuring that all the information
contained in the Authorized
Trader Contact Registration Form
Temains current so that PBOT can
immediately reach the Authorized
Trader Contact at all times when
block trades are being submitted
or executed or orders or quotes
are resting in, being submitted to,
or are being executed through the
firm’s Member ID.>

In addition, because an
Authorized Trader Contact must
be immediately reachable at all
times when business is being
transacted through the firm’s
Member ID, PBOT allows firms
to designate and register an
“Alternative Authorized Trader
Contact,” who performs the role
and accepts the duties and

' PBOT Rule E2(a) defines
“Authorized Trader Contact” and
“Member ID.”

? PBOT Rule E7(b) and (c); see also
Attachment A for a copy of
“Authorized Trader Contact
Registration Form.”

3 PBOT Rule E7(f).

October 3, 2006



ATTACHMENT B
PBOT
Authorized Trader Contact De-registration or Transfer Form

Requests for de-registration or transfer become effective only upon approval of PBOT. A Authorized Trader
Contact is de-registered at the close of business on the trading day that a completed form is submitted before 6:00
p.m. (EST) to, and approved by, PBOT (unless de-registration or transfer is requested for a future date).

Requested De-registration
Date (ciose of business):

Member Name:

Member ID:

Name of Authorized Trader
Contact:

Name of Alternative
Authorized Trader Contact:

Name of Authorized Person
Contact to be transferred to:
(use separate form for new
registration)

COMMENTS:

Authorized by:

PBOT staff (printed name) For official use only

Signature of authorized PBOT staff and Date

PBOT staff contact number and E-mail Address

PBOT Notice to Members 02-2006 October 3, 2006



PBOT)

PHILADELPHIA GORAD OF TRADE ©
ATTACHMENT B

Trading Days and Hours

Product: Daily ExpiryTM US Dollar 3-Month BBA LIBORTM Futures
Contract

7:30 a.m. to 8:00 a.m. (ET)
Pre-Opening: Order Entry and Open-Interest Dissemination

The PBOT will open for order entry at 7:30 am (ET) each trading day, at which time the exchange
will transmit a control message "Start of Day” to members and member organizations (collectively
“members’), after which authorized persons can log-on to PBOT XL. Once logged on, an
authorized person can use any application function provided by the application program interface
(“API”) to enter orders, including functions to submit, revise, and withdraw certain types of orders.
During this period no matching of orders occurs, but authorized persons can enter limit orders
and “Good 'til Canceled” orders.

8:00 a.m. to 8:20 a.m. (ET)
Quote Entry for PBOT Opening Begins

Before 8:00 a.m. (ET) market makers can only enter quotes to test the PBOT XL quote
processing system using an application-level "ping” to verify application connectivity. Beginning
at 8:00 a.m. (ET), PBOT market makers can enter quotes for consideration in the opening trade
calculation for that trading day.

8:20 a.m. (ET)

PBOT Trading begins
Trading begins at 8:20 a.m. (ET), at which time authorized persons may use all trade
application functions provided by the API.

4:15 p.m. (ET)

Market Close

The PBOT market will close at 4:15 p.m. (ET) each trading day, at which time no further orders or
quotes are accepted.

PBOT Notice to Members 01-2006 October 3, 2006



responsibilities of an Authorized
Trader Contact, when the primary
Authorized Trader Contact is
unavailable.’ In any event, if the
member elects to designate an
Alternative Authorized Trader
Contact, the primary Authorized
Trader Contact remains
responsible for ensuring that her
or she or the Alternative
Authorized Trader Contact are
always immediately available
when business is being transacted
through the firm’s Member ID.

Duties and
Responsibilities

An Authorized Trader Contact is
responsible—and serves as the
first point of contact—for all
block trades and orders or quotes
submitted through the firm’s
Member ID, including any orders
submitted through automated
order-routing systems.

In addition, PBOT Rule E7(c)
imposes four duties and
responsibilities on each
Authorized Trader Contact. First,
at PBOT’s request, the
Authorized Trader Contact must
have the authority to modify or
withdraw any order, quote, or
block trade submitted under the
firm’s Member ID.° Second, the
Authorized Trader must have the
ability to immediately identify
the source of the order, quote, or
block trade. Third, the
Authorized Trader must ensure

* See Attachment A for a copy of

“Authorized Trader Contact
Registration Form.”

5 PBOT E7(6X1).
© PBOT E7(cX2).

that all orders, quotes, or block
trades submitted to PROT
comply with all applicable
provisions of the Commodity
Exchange Act, regulations of the
Commodity Futures Trading
Commission, the rules of PROT
(including Notices to Members),
and all PBOT regulatory and
operational orders and
procedures,” Finally, an
Authorized Trader Contact must
ensure that any person
conducting business through the
firm’s Member ID is competent
and appropriately trained.

Suspension, Transfer,
or De-Registration

PBOT may, in its sole discretion,
suspend or revoke the registration
ofan Authorized Trader Contact.
For example, PBOT may suspend
or revoke the registration of an
Authorized Trader Contact
because of recurring
unavailability when the firm’s
Member ID is in use or the
contact’s repeated inability to
immediately identify the source
of each quote, order, or block
trade submitted through the
firm’s Member ID.

With PBOT’s consent, a member
or Authorized Trader Contact
may request to terminate or
transfer the registration of the
Authorized Trader Contact. To
terminate or transfer the
registration of an Authorized
Trader Contact, the member or
Authorized Trader Contact must
complete and submit to the PROT
an “Authorized Trader Contact

7 PBOT E7(cX3).

* PBOT E7(c)(4).

PBOT Notice to Members 02-2006

De-Registration or Transfer of
Form.”” However, for the
protection of the market,
members, and customers, PBOT
may, in its sole discretion, refuse
to accept a request to terminate
the registration of an Authorized
Trader Contact, postpone the
effective date of the termination
of registration, or otherwise place
terms or conditions before or
after the effective date of de-
registration or transfer.

Trader ID

Finally, to further enhance our
audit trail, PBOT requires each
member to identify the person
submitting each order, quote, or
block trade by attaching a unique
identifier, or Trader ID, at the
time of submission to the
PBOT."° Each member must
ensure that an appropriate Trader
ID is submitted to PBOT at the
time of each order, quote, or
block trade submission or
revision.

© 2006 PBOT. Allrights
reserved. Through Notices to
Members, PBOT attempts to
present information to readers in
an easily understandable format.
However, if any inconsistency
exists between this Notice and
PBOT’s Rules, PBOT’s Rules
prevail and provide the
authoritative source of
information.

° See also Attachment B of this
Notice for a copy of the “Authorized
Trader Contact De-Registration or
Transfer Form.”

1© PROT Rule E2(a) defines “Trader
ID.” See also Rule E7(e).

October 3, 2006



Notice to Members 03-2006

Executive Summary

Through this Notice to Members
and pursuant to the Philadelphia
Board of Trade (“PBOT”) Rule
E11(b), PBOT has established the
minimum initial and maintenance
margin that members and
member organizations must
collect from customers and
maintain for firm and market
maker trading.

Margin Levels

Pursuant to PBOT Rule E11(b),
through this Notice, PBOT has
established the initial and
maintenance margin levels for
customer accounts as well as for
firm and market maker accounts
for each Daily ExpiryTM US
Dollar 3-Month BBA LIBORTM

Futures Contract as:

PBOT Notice to Members 03-2006

These margin requirements are
effective as of October 6, 2006,
and remain in effect until further
notice from the exchange.

In addition to Rule E11, members
and member organizations are
urged to consult the Margin
Handbook published by the Joint
Audit Committee if they have any
questions regarding margin
generally.

Please direct any questions
concerning this Notice to Walt
Smith, Vice President and
General Manager, at (215) 496-
5532.

© 2006 PBOT. All rights
reserved. Through Notices to
Members, PBOT attempts to
present information to readers in
an easily understandable format.
However, if any inconsistency
exists between this Notice and
PBOT's Rules, PBOT’s Rules
prevail and provide the
authoritative source of
information.

October 3, 2006



. Philadelphia Board of Trade PBOT

Assubsidiary of the
Philadelphia Stock Exchange

1900 Market Street
Philadelphia, PA 19103-3584

Telephone: 215-496-5000
Fax: 215-496-5399

Rule Self-Certification

October 3, 2006

Office of the Secretary Om
Commodity Futures Trading Commission a m
Three Lafayette Center bs
1155 21° St, NW. “Ss

Washington, D.C. 20581

Reference File SR-PBOT-2006-06: Notices to Members

Ladies and Gentlemen:

Pursuant to Commission Rule 40.6, the Philadelphia Board of Trade (“PBOT”) proposes
to issue the following Notices to Members, copies of which are attached:

Notice to Members 01-2006: Days and Hours of Operation
Notice to Members 02-2006: Authorized Trader Contacts
Notice to Members 03-2006: Margin

These Notices to Members will be effective on October 6, 2006.

No opposing views were expressed to PBOT by its board, its Executive Committee or its
members concerming these Notices to Members.

The PBOT certifies that these Notices to Members comply with the Commodity
Exchange Act and the mules thereunder.

Yours truly,

CMAPS

C. Robert Paul
Executive Vice President
and General Counsel

ce: Mr. Allen J. Cooper
Ms. Jane Croessmann


ATTACHMENT A
PBOT
Authorized Trader Contact Registration Form

[ Member Name: l | Member ID: | |

I am an employee or associated person of the member firm listed above. I confirm that I understand the
obligations of being an Authorized Trader Contact on PBOT, and request registration as an Authorized Trader
Contact or Alternative Authorized Trader Contact for the products that the above-referenced member firm is
authorized to trade on PBOT. With my signature on this form, I agree to be subject to, and comply with, all
applicable provisions of the Commodity Exchange Act, regulations of the Commodity Futures Trading
Commission, rules of the PBOT (including Notices to Members), and all PBOT regulatory and operational orders
and procedures.

Full Name: Authorized Trader Contact Signature

Title Direct Telephone No.

E-mail Address Alternative Telephone
No.

Date for requested Market Maker for

activation of registration PBOT (Y/N)

Full Name: Alternative Authorized Trader Contact | Signature

Title Direct Telephone No.
E-mail Address Alternative Telephone
No.
. Authorized by:
PBOT staff (printed name) For official use onty

Signature of authorized PBOT staff and Date

PBOT staff contact number and E-mail Address

PBOT Notice to Members 02-2006 October 3, 2006



Executive Summary

The Philadelphia Board of
Trade (“PBOT”), pursuant to
PBOT Rules E4 and E5, is
publishing its days and hours
of operation for 2006 and
2007. In addition, through
this Notice the PBOT is
publishing its market opening
sequence for trading days.

Trading Days

Set forth in attachment A to
this Notice are the holidays
recognized by the PBOT for
2006 and 2007. PBOT will be
closed on these designated
holidays but otherwise open
for business on all other
business days unless the
PBOT determines otherwise
and notifies members through
a Notice to Members or other
appropriate means.

Trading Hours

Set forth in attachment B are
the trading hours on the
PBOT, as well as the market
opening sequence and timing.
PBOT will follow these hours
of operations and market
opening sequence on each

PBOT Notice to Members 01-2006

Notice to Members 01-2006

trading day unless it notifies
members otherwise through a
Notice to Members or other
appropriate means.

Please direct any questions
concerning this Notice to
Dennis Boylan, Director,
PBOT Market Operations, at
888-353-8114,

© 2006 PBOT. All rights
reserved. Through Notices to
Members, PBOT attempts to
present information to readers
in an easily understandable
format. However, if any
inconsistency exists between
this Notice and PBOT’s Rules,
PBOT’s Rules prevail and
provide the authoritative
source of information.

October 3, 2006



PBOT!

PHILADELPHIA BOARD CF TaDE @
ATTACHMENT A

Holidays for Calendar Years 2006-2007

During 2006 and 2007, the Exchange will be open Monday through Friday,
except for the following days:

Holiday Month Date | Year
Columbus Day October 9 | 2006
Thanksgiving Day November 23 | 2006
Christmas Day December 25 | 2006
New Years Day January 1 | 2007
Birthday of Martin Luther King, Jr. January 15 | 2007
Washington's Birthday February 19 | 2007
Memorial Day May 28 | 2007
Independence Day July 4 | 2007
Labor Day September 3 | 2007
Columbus Day October 8 | 2007
Veteran's Day November 12 | 2007
Thanksgiving Day November 22 | 2007
Christmas Day December 25 | 2007

PBOT Notice to Members 01-2006 October 3, 2006