i dined ither-of- the three (3) full t ibed4
Contract-en-the-p: tr rs 5 a } P

bel. h-a-level,-they-shall-belisted for trading-on-the following 4 1, ith isted-level

pu d ce Pa :
and-(b)Gi):]

(i) At the time Sugar Options for any Regular Option Month are first (1°) listed for trading pursuant
to Rule 11.22, they shall be listed with seven (7) Strike Prices at intervals specified in paragraph (b)
above for Puts and Calls. The first (1°) Strike Price will be set at the prescribed level equal to the
Settlement Price for the Underlying Futures Contract on the previous trading day, or if such
Settlement Price is not equal to any such prescribed level, then at the next prescribed level above such
Settlement Price. The other six (6) Strike Prices shall be at each of the three (3) prescribed levels next
above and the three (3) prescribed levels next below the first (1) Strike Price. At the time Sugar
Options for any Serial Option Month are first listed for trading pursuant to Rule 11.22, they shall be
listed with all the Strike Prices of the next Regular Option Month with an expiration subsequent to the
Serial Option.

(ii) Whenever the Strike Prices of the listed Options for any Regular or Serial Option Month do not
include the seven (7) Strike Prices at intervals specified above based upon the Settlement Price of the
Underlying Futures Contract on the previous trading day, Strike Prices at the prescribed levels shall
be listed for trading.

(iii) Any listing of Strike Prices prescribed by the Board or the President under this Rule shall be
made effective upon adoption or as otherwise determined by the Board or the President.

(d) An Option shall be delisted if for ten (10) consecutive trading days no Transaction is executed,
and there is no open position, in such Option; provided, however, that no Option shall be so delisted if it
has a Strike Price which is at the first (1°) full-cent prescribed level above the Settlement Price of the
Underlying Futures Contract on the previous trading day, or is at either of the three (3) prescribed full-
cent levels above or below such level, or any of the intervening half-cent Strike Prices set forth in
subparagraphs (b)(i) and (b)(ii); and provided further that no Option shall be so delisted if there is an
Option in another class with the same Strike Price that does not otherwise qualify for delisting; and
provided further that, in the case of Serial Options and the next Regular Option Month with an expiration
subsequent to the expiration of the Serial Option(s), no Option shall be so delisted unless it can be
delisted for any Serial Option Month and such next Regular Option.

[(e)-On-the-trading day that anyRegular Option-Month-that deferred. th-_become: by
thor: £ Serial: Opt hall-beisted-for-tradine- ii h Resul. Serial-Ovti
ry 7 P S eel P

Month having Strike Prices set-i ord: ith-the-p: ibedtlevels-and. ibed-intervals-set-forth

)-One-)-full +-Strike-Py +-+th ibedevel-which 1-+e-the-Setth +P; fe

he Und: Fut: fay Hy a: £ such Settl Pp

# tract-on-the-pi trading -day,-or, tt + equal
t ¥-such-p ibed Jevelthen-at-th +sueh-pi ibedtevelabi h-Settl + Price-and



295

-5 ki 948 EW YORK
dd BOARD OF TRADE®

OFC. GF Tis SECRETARIAT World Financial Center
One North End Avenue
New York, New York 10282

BY ELECTRONIC TRANSMISSION

05-35
September 8, 2005

Ms. Jean A. Webb

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 Rule 11.24 -
Submission Pursuant to Section 5c(c)(1) of the Act and Regulation 40.6

Dear Ms. Webb:

Pursuant to Section 5c(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 Rule 11.24, attached as Exhibit A.

The amendments change the strike price interval for Sugar Options to 25 points starting
at $.0050 up to $.1000 per pound, to 50 points starting at $.1000 up to $.1500 per pound and 100
points at $.1500 per pound and above. The narrower strike prices will increase liquidity in Sugar
Options, allow hedgers to more precisely tailor their hedges and allow over-the-counter market
makers to improve their pricing.

In addition, the amendments provide for the automatic listing of strike prices, the at-the
money strike and 3 strikes above and 3 strikes below the at-the-money strike.

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

The amendments were adopted by the Exchange’s Board of Governors on April 13, 2005.
They will become effective on September 26, 2005.


-2-

Opposing views were expressed by members and others with respect to the amendments.
Those opposing the narrower strike price intervals expressed the view that this would cause too
many strike prices to be listed for trading. This would have a negative impact on liquidity,
dampen volatility and diminish the tightness of the bid/ask spread in the currently listed strike
prices to the detriment of existing users.

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 11.24. Strike Prices

(a) Trading shall only be conducted in Regular or Serial Options having Strike Prices determined in
accordance with this Rule.

(b) The Strike Prices of Options that are listed for trading shall be at levels (the "prescribed levels")
set in intervals (the "prescribed intervals") as follows:

(i) Strike Prices shall be at levels which are at intervals of one-quarter cent ($.0025) commencing at
$.0050 per pound up to $.1000; at levels which are at one-half cent ($.0050) commencing at $.1000
per pound up to $.1500 per pound; and at levels which are one cent ($.0100) at $.1500 per pound and
above. [In—th £ al] _Regular_Options-Contracts—trading_on—the—first-")twe-(2)-nearby.

(c) Except as the Board or President may from time to time prescribe otherwise, Sugar Options shall
be listed for trading with particular prices for each Option Month as follows:

S) Strike Pri At-the-ti S Opti £
Ste - gar-Opt
Serial-Option Month are first listed for-trad: +10 Rule-H_22, they-shall-be listed -with all
the-Strike-Pri £ the-next-Resular-Option—-Month—with. irati by: +-to-the-Serial
s PF Pi
GDh the Strike Pri £the-listed-Options-f Regul Seri ‘
(en 4 P ny Regi -Option Menth-de-net
Jude-the-first-4"}-p ibed-full cent Jevel-above the Setth + Price-for the Underlying Fut

EXHIBIT A