Ms, Jean A. Webb
November:29, 2005
Page 5 of 5

Appendix 2
INTERPRETATIONS & SPECIAL NOTICES RELATING TQ CHAPTER 1

INTERPRETATION OF RULE 135.4. REGARDING ALLOWABLE SPREADS FOR GEM MEMBERS

Rule 135.A. provides that GEM members may not while on the floor of the Exchange enter orders for products of other Divisions
except for bona fide spread transactions involving products within the GEM Division and that GEM members may not solicit
business from the floor of the Exchange except for business in products traded in the GEM Division and bona fide spread
involving such products.

The only allowable spreads involving non-GEM products that GEM members may enter into or solicit while on the trading floor
are listed below:

GSCI With Live Cattle and Lean Hogs
Russell 2000 With S&P 500, S&P Mid-Cap, E-Mini S&P 500
E-Mini Russell 1000 With E-Mini S&P 500

S&P/Barra Growth and Value With S&P 500, S&P Mid-Cap, E-Mini S&P 500
Live Cattle Serial (Odd) Months With Live Cattle Even Months*

East European Currencies With Euro FX

European style currency options With British pound, Canadian dollar, Euro FX,

Japanese yen and Swiss franc futures or
American style options on these futures

CMESINDEXTM With Euro FX, Japanese yen, British pound, Swiss
franc, Australian dollar, Canadian dollar,
Swedish krona

E-Mini NASDAQ Composite With E-Mini NASDAQ-100, E-Mini S&P 500, E-

Mini S&P MidCap 400, E-Mini Russell 2000,
S&P SmallCap 600, E-Mini Russell 1000,
Financial SPCTR, Technology SPCTR.

CPI With Eurodollar
Yen Denominated Nikkei 225 With Dollar Denominated Nikkei 225
HICP With Eurodollar, CPI

*Provided the GEM member also maintains a Serial Month Live Cattle Permit.

When such spreads are executed on a legged basis, the GEM leg of the spread must always precede the non~GEM leg with the
exception of the Live Cattle Serial Months/Live Cattle Even Months spread where either leg may be executed first, Please note
that these restrictions do not apply to spreads in which all of the component parts are GEM products.


cme @

Chicago Mercantile Exchange
20 South Wacker Drive 312/930.1000 tel
Chicago, IL 60606-7499 312/466.4410 fax

www.cme.com

November 29, 2005

Ms. Jean A. Webb

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21* Street, NW an 9
Washington, DC 20581 a

RE: Section 5c(c) and Regulation $40. 6(a) Submission,

Exchange Certification for Amendments to INTERPRETATION OF RULE ka.
REGARDING ALLOWABLE SPREADS FOR GEM MEMBERS ¢

CME Submission # 05-128. rn

c
lon
a

Dear Ms. Webb:

Chicago Mercantile Exchange (“CME” or “Exchange”) hereby notifies the Commission
under the exchange certification procedure of amendments to INTERPRETATION OF RULE
135.A. REGARDING ALLOWABLE SPREADS FOR GEM MEMBERS to add spreads
between (1) the CME® Russell 2000® and the CME E-mini® S&P 500® contracts, (2) the CME
S&P 500/Barra® Growth and the CME E-mini S&P 500 contracts and (3) the CME S&P
500/Barra Value and the CME E-mini S&P 500 contracts to the list of allowable spreads for
GEM members.

GEM members trading the listed spreads on the trading floor are required to give up the
non-GEM eligible leg of the spread to be executed by a division-qualified broker. The terms of
the interpretation allow them to avoid leaving the trading floor to have the non-GEM eligible leg
of the spread executed. In addition, GEM members trading spreads pay lessee clearing fee rates
for the GEM eligible leg of the spread (member clearing fee rates for GEM division products)
and non-member clearing fee rates for the non-GEM eligible leg of the spread.

This change will be effective immediately upon notification to shareholders and members
who will be informed of these changes in CME Update 05-12 to be published on Monday,
December 5, 2005. The Exchange certifies that the amendments to INTERPRETATION OF
RULE 135.4. REGARDING ALLOWABLE SPREADS FOR GEM MEMBERS complies
with the Act and rules thereunder.

The text of this change is provided in Appendix | to this document below - with additions
underlined. A clean copy of the amended interpretation is provided in Appendix 2.


Ms. Jean A. Webb
November 29, 2005
Page 3 of 5

Please do not hesitate to contact Ms. Lori Aldinger at 312-930-2337 or
laldinge@cme.com if any questions arise during the processing of this submission. Please
reference our CME Submission #05-128 on all future correspondence for this submission.

Sincerely,

y fp igg=

John W. Labuszewski, Director
Research & Product Development



Ms. Jean A. Webb
-November 29, 2005
Page 4 of 5

Appendix 1

INTERPRETATIONS & SPECIAL NOTICES RELATING TO CHAPTER 1

INTERPRETATION OF RULE 135.A. REGARDING ALLOWABLE SPREADS FOR GEM MEMBERS

Rule 135.A. provides that GEM members may not while on the floor of the Exchange enter orders for products of other Divisions
except for bona fide spread transactions involving products within the GEM Division and that GEM members may not solicit
business from the floor of the Exchange except for business in products traded in the GEM Division and bona fide spread
involving such products.

The only allowable spreads involving non-GEM products that GEM members may enter into or solicit while on the trading floor
are listed below:

GSCI With Live Cattle and Lean Hogs
Russell 2000 With S&P 500, S&P Mid-Cap, E-Mini P 500
E-Mini Russell 1000 With E-Mini S&P 500

S&P/Barra Growth and Value With S&P 500, S&P Mid-Cap, E-Mini 500
Live Cattle Serial (Odd) Months With Live Cattle Even Months*

East European Currencies With Euro FX

European style currency options With British pound, Canadian dollar, Euro FX,

Japanese yen and Swiss franc futures or
American style options on these futures

CMESINDEXTM With Euro FX, Japanese yen, British pound, Swiss
: franc, Australian dollar, Canadian dollar,
Swedish krona
E-Mini NASDAQ Composite With E-Mini NASDAQ-100, E-Mini S&P 500, E-

Mini S&P MidCap 400, E-Mini Russell 2000,
S&P SmallCap 600, E-Mini Russell 1000,
Financial SPCTR, Technology SPCTR.

CPI With Eurodollar
Yen Denominated Nikkei 225 With Dollar Denominated Nikkei 225
HICP With Eurodollar, CPI

*Provided the GEM member also maintains a Serial Month Live Cattle Permit.

When such spreads are executed on a legged basis, the GEM leg of the spread must always precede the non-GEM leg with the
exception of the Live Cattle Serial Months/Live Cattle Even Months spread where either leg may be executed first. Please note
that these restrictions do not apply to spreads in which all of the component parts are GEM products.