GI NEW CORK.

World Financial Center
One North End Avenue
New York, New York 10282

BY ELECTRONIC TRANSMISSION
06-36
December 14, 2006
Ms. Eileen A. Donovan
Acting 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 Sugar No. 11 Rules 11.07(a), 11.23 and 11.43 -
Submission Pursuant to Section 5¢(c)(1) of the Act and Regulation 40.6

Dear Ms. Donovan:

Pursuant to Section 5¢(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 Sugar No. 11 Rules 11.07(a), 11.23 and 11.43,
attached as Exhibit A.

The amendment to Rule 11.07(a) adds the Emirate of Dubai to the list of destinations for
which settlement is to be made on the basis of net landed weights and tests taken at the port of
discharge. The addition of Dubai to the list of destination weight ports is based upon the quality
of standards and practices in Dubai. In addition, the amendment is consistent with commercial
market practice in the raw sugar trade. There were some individuals opposed to the amendment
because they felt that the Sugar No. 11 futures contract should be, and remain, predominantly a
shipping weight contract.

The amendments to Rules 11.23 and 11.43 change the last trading day for all Sugar
Option and Sugar Options on Futures s Spread contracts from the 2" Friday of the calendar month
in which the option expires to the 15" calendar day of the month in which the option expires, or,
if such day is not a business day, the first business day after the 15" calendar day. The
amendments provide additional trading days for each options contract which will benefit market
users and will not significantly impact the Exchange’s ability to ensure an orderly liquidation of
the underlying futures contract.

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


-2-

The Exchange’s Board of Governors adopted the amendments on December 13, 2006.
The amendment to Rule 11.07 will become effective with the listing of March 2009 futures
contract; the amendments to Rule 11.23 will become effective with the listing of the options
contracts which have March 2009 as the underlying futures contract; and the amendments to
Rule 11.43 will become effective with the Options on Spreads contracts having the July 2007
contract as the front month. As stated above, there were opposing views with respect to the
amendment to Rule 11.07(a). There were no opposing views with respect to the amendments to
Rules 11.23 and 11.43.

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

ce: Riva Adriance
Thomas Leahy
CFTC, Division of Market Oversight
Allen Cooper
CFTC, New York Regional Office


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

Rule 11.07. Final weights and tests are to be determined as follows:

(a) If the sugar is to be shipped to Belgium, Canada, the Emirate of Dubai, Finland, France, Germany,
Holland, Ireland, Japan, Malaysia, Morocco, New Zealand, Portugal, Singapore, Sweden, the United
Kingdom or the United States, settlement is to be made on net landed weights and tests taken at port of
discharge as customary at said port in accordance with the procedures set forth in paragraph (b) below;
provided, however, that regardless of the destination, the Receiver shall have the right, declarable at the
time of nomination of the carrying vessel, to require that final settlement be based upon shipper's weights
and tests determined as is customary at loading port at time of loading.

(REMAINDER OF RULE UNCHANGED)
Rule 11.23. Last Trading Day

The Last Trading Day for any Regular or Serial Option Month shall be the [seeond-2TM)Priday]
fifteenth_15"" calendar day of the calendar month in which such Regular or Serial Option expires;
provided, however, that, in the event the Exchange is closed on such [Friday] day, then the Last Trading
Day shall be the next succeeding Business Day. [.:

fatthe Exch: i: 1, db. hh Erid. + desi ted-Exch: Held. hich-h 4y
} 5 y ee Bt 7
se-designated_f th: (4) prior theretethet "Last-Trading-Day"-shal +h
trading day preceeding such Frday-and
(bf the Exch. i 1, db h-Frid, £, thi thet “Last-Tradi Dayv''-shall
{8} AE ASH y a0 a B-Day
the first 1") tradi i; ft, hE, J
EF ig aay .

Rule 11.43. Last Trading Day

The Last Trading Day for any SSO series pair shall be the fifteenth (15"") calendar day of the calendar
month in which the Option contract of the first expiring delivery month in the pair expires; provided
however that, in the event the Exchange i is closed on Such day, then the Last Trading Day shall be the next
succeeding Business Day [daya ugar 8 as d uida

the first thin-the-pair]
P y Par].

EXHIBIT A