i (see (see #1,7,12)! [
| #1,7,12) ¢ i

Soybean Meal , 720. +4000 15250.) 200.7 200
(see (see #1,7,12): H
#1,7,12) | i i



SRT BL 2 24

TAQLAT
CRC IAAL

July 27, 2005

Ms. Jean A. Webb

Secretary

Commodity Futures Trading Commission

Three Lafayette Center

1155 21" Street, N.W.

Washington, D.C. 20581
Reference File #2575.01
Non-Material Agricultural
Rule Change

Dear Ms. Webb:

Pursuant to Commission Regulation 40.4(b), the Chicago Board of Trade (CBOT®) hereby
submits the following:

- Amendment to Regulation 425.01 per the attached text (addition bold and
underlined; deletion bracketed and struck through).

The referenced amendment will reduce the Exchange’s reportable position level for South
American Soybean futures from 150 contracts to 25 contracts in any one month. The Exchange
has concluded that this revised reportable position level is appropriate given the current level of
open interest in this contract.

The CBOT intends to implement this amendment no sooner than ten days after the
Commission’s receipt of this submission.

There were no opposing views concerning this amendment.

The CBOT certifies that this amendment complies with the Commodity Exchange Act and the
tules thereunder.

Sincerely,

Paul J. Draths
Vice President and Secretary

b081605


Deletions are [bracketed-with-strikethrough]
Additions are bold and underscored

425.01 Position Limits -
(a) For the purposes of this Regulation, the following are definitions of titles used in position limit chart-

Spot Month- Spot month futures-equivalent position limit net long or net short effective at the start of
trading on the first business day prior to the first trading day of the spot month.

Single Month- Futures-equivalent position limit net long or net short in any one month other than the
spot month.

All Months -Position limit net long or net short in all months and all strike prices combined. Note:
Long futures contracts, long call options, and short put options are considered to be on the long side
of the market while short futures contracts, long put options, and short call options are considered to
be on the short side of the market. For each commodity, the futures-equivalents for both the options
and futures contracts are aggregated to determine compliance with the net long or net short same
side position limits.

Reportable Futures Level-Reportable futures position in any one month.

Reportable Options Level-Reportable options position in any one month in each option category.
Note:0ption categories are long call, long put, short call, and short put.

Net Equivalent Futures Position-Each option contract has been adjusted by the prior day's risk
factor, or delta coefficient, for that option which has been calculated by the Board of Trade Clearing
Corporation.

For the purpose of this Regulation:

(i) An option contract's futures-equivalency shall be based on the prior day's delta factor for the
option series, as published by the Board of Trade Clearing Corporation. For example, 8 long
put contracts, each with a delta factor of 0.5, would equal 4 futures-equivalent short
contracts.

(ii) Long futures contracts shall have a delta factor of +1, and short futures contracts shall have a
delta factor of -1.

(iii) Long call options and short put options shall have positive delta factors.

(iv) Short call options and long put options shall have negative delta factors.

(v) An eligible option/option or option/futures spread is defined as an intra-month or inter-month
position in the same Chicago Board of Trade commodity in which the sum of the delta factors

is zero.

(b) Except as provided in Regulations 425.03, 425.04 and 425.05, the maximum positions which any
person may own, control, or carry are as follows:

(Note: All position limits and reportable positions are in number of contracts and are based on futures
or *Net Equivalent Futures Positions.

*Please see section (a) of this Regulation for definition.



*SPOT *SINGLE *ALL *REPORTABL *REPORTABLE

E
ICONTRACT MONTH MONTH MONTH | FUTURES / OPTIONS LEVEL
LEVEL i
Bund _ None | None} None __ 1,000
Bobl None | None | None; _—_—800 |
Schatz —_ None None__|___None Aen 900
10-Year Interest Rate Swap None | __ None ___None | 500
5-Year Interest Rate Swap _ ___None None None 500. . _
ICBOT Dow Jones Industrial : None } None : 50,000 | 200 i 200
lAverageTM Index H H | (aggregate | H
H | DJIA limit, |
£ i see #9) :
ICBOT mini-sized DowTM ($5 None None 50,000 200 | 200
multiplier) (aggregate |
| DJIA limit, | '
| see #9) | i
ICBOT Dow Jones-AIG i H :
Commodity Index” None | None 15,000 __ _
ICBOT 5,000 oz. Silver 1,500 | 6,000 6,000 | __
ICBOT 100 oz. Gold 3,000; 6,000 6,000: _|
|CBOT mini-sized Silver 4,500 {| 1,500 | 3,000 |
ICBOT mini-sized Gold 4,000  ; 4,000 6,000
U.S. Treasury Bonds None None None _ 1,500 1,500
Mini-sized U.S. Treasury Bonds. None _|__None None | _1,500 .
U.S. Treasury Notes (5yr.) None None _None 2,000 2,000
U.S. Treasury Notes (6 1/2- None None None 2,000 2,000
1Oyr.) i :
U.S. Treasury Notes (2yr.) None | None None i 1,000 1,000
130 Day Fed Fund | None __|_None _None_ 600 600
10-Year Municipal Note Index i 5,000 | None : 5,000 300 i
i j i
Mini-sized Eurodollars L10,000 | 10,000 | 10,000 400
Corn and CBOT mini-sized 600 9,500 15,500 250 250
Com (aggregate, | (aggregate; (aggregate, | (individual, see
see #10) , see #1, | see #1, 3, #11)
_ 10, 12) 10, 12) H
Soybeans and CBOT mini- | 600 5,000 7,750 | 150 H 150
sized Soybeans (aggregate, : (aggregate; (aggregate, / (individual, see:
see #10) | ,see#1, | see#i,4,{ #11) |
} 10,12) | 10,12) if
[South American Soybeans i 600 3,500 | 5,500 | [459] | “|
7 (see #12) | (see #1) | (see#1) | 25 i
Wheat and CBOT mini-sized 600 4,000 5,250 | 150 { 150
Wheat (aggregate, |(aggregate| (aggregate, | (individual, see!
| see #8, 10) | ,see#1, | see#1,7, | #11) |
- i 10,12) | 10,12) | i
Oats 600. «1,200 1,750. | 60 | 60
(see #1,12)! (see#1,6, | i
. i 12) i
Rough Rice 600 + 1,000 ; 1,000} 50 i 50
(see#5) | iL (see#2) | i

Soybean Ol AO 4000 5.250 200200