February 8, 2007
Via E-Mail

Office of the Acting Secretary

Commodity Futures Trading Commission

Three Lafayette Centre s
1155 21st Street, N.W.
Washington, D.C. 20581

Re: Rule Certification. NYMEX Submission 07.18: Notification of
Amendments to NYMEX Division Rule 6.18 and COMEX Division =
Rule 104.81 Regarding CTI Type 3 Trades. tow

Dear Ms. Eileen Donovan:

The New York Mercantile Exchange ("NYMEX" or the "Exchange") is notifying the
Commodity Futures Trading Commission (““CFTC” or “Commission”) of amendments to
NYMEX Division Rule 6.18 and COMEX Division Rule 104.81.

Effective February 12, 2007, the amendments to NYMEX Division Rule 6.18 and
COMEX Division Rule 104.81 clarify and make consistent across both Divisions the
recordkeeping requirements of Members who execute CTI 3 orders for other Members.
Specifically, on either Division, when receiving an order from another Member for that other
Member’s personal account, or an account over which that other Member has control, the
executing Member must either receive and retain, or immediately prepare and retain an order
ticket that satisfies all the order memorandum requirements that pertain to customer orders,
UNLESS such order is for electronic execution and may immediately be entered into Globex®.

Pursuant to Section 5c(c) of the Commodity Exchange Act (“Act”) and CFTC Rule 40.6,
the Exchange hereby certifies that the attached rule amendments comply with the Act, including
regulations under the Act.

If you have any questions, please contact Nancy Minett, Vice President, Compliance, at
(212) 299-2940, or myself at (212) 299-2897.

Sincerely,
Thomas F. LaSala
Chief Regulatory Officer

ce: Nancy Minett
Brian Regan



(Additions are in bold/underline; deletions are in bold/strikethrough.)
NYMEX Division Rule 6.18, Numbering and Time Stamping Orders

(A)(i) When an FCM receives an order from a customer a memorandum of the order shall be made in non-erasable
ink which shall identify the customer by symbol or account number and shall be time stamped when received and
time stamped when a report of the execution is made, and, in addition, in the case of option customers’ orders, the
memorandum shall be time stamped to the nearest minute the order is transmitted for execution on the floor.

(ii) When a Floor Member, FCM, Member Firm, or Floor Brokerage Business receives an order, on the Exchange
Floor, from a customer, a memorandum of the order shall be made in non-erasable ink which shall identify the
customer by symbol or number and which shall be time stamped when received and time stamped when a report of
the execution is first made. The Floor Member, FCM, Member Firm or Floor Brokerage Business shall indicate the
customer account number, clearing member number and customer type indicator code on transfer information
furnished to the Exchange.

(B)(i) When an order is received from a Member whe-4s-on-the-fleor of the Exchange and trading for his own
account or an account controlled by such Member (a Type 3 trade), a memorandum of the order shall be made
maintained by the executing broker in non-erasable ink which shall be numbered, or identified by symbol and shall
identify the Member initiating the order by symbol or account number and which shall be time stamped when
received and time stamped when the report of execution is made, unless such order is for electronic execution
and may be immediately entered into Globex. A Member executing a Type 3 trade for another Floor Member
by open outcry must also indicate in the account imn of his or her trading card the alphanumeric tradin:
acronym of the member for whom the trade is executed.

(ii) The requirements of paragraph (B)(i) shall not apply to transactions that are executable as part of intermarket
spread transactions or options offset transactions, provided that the Member initiating the order personally executes
one or more legs of the transaction and the transaction is recorded on a pit card or an Approved Handheld that is
submitted to the Exchange within one minute of execution in accordance with the requirements of Rule 6.10(A).
However, with respect to all Type 3 trades, the executing floor broker shall indicate on the transfer information
required by the Exchange to be submitted in conjunction therewith, the alpha code (badge symbol) of the Member on
whose behalf the trade was executed.

(C) Floor Members who execute customer and Type 3 orders on the Exchange floor must retain one ply or copy of
the customer order memorandum or Type 3 order memorandum, if applicable, in accordance with Exchange Rule
8.50(A). Floor Members may be exempt from this requirement if written notice, from an FCM or Member Firm, is
given to the Compliance Department acknowledging that it is the custodian of a Floor Member's daily trading
records.

COMEX Division Rule 104.81, Order Tickets

(a) General Requirements. A floor member who receives a verbal order from a customer etherthan-another
rem senton-the fh fthe-Exchange shall immediately upon receipt thereof prepare a written record of
such order which shall include the account identification, order number, and such other information as may be
required by CFTC Regulation 1.35(a-1)(2) on such form as may be prescribed by the Exchange.

For purposes of this Rule, “account identification" information for an order placed on behalf of (i) a pool, as that term
is defined in CFTC Regulation 4.10(d), (ii) a qualifying entity under CFTC Regulation 4.5 for which a notice of
eligibility has been filed with the Commission, or (iii) a series of accounts within a managed account program, as that
term is defined in CFTC Regulation 15.00(i), may be recorded either in the form of account code for each account in
which the order, when filled, will be allocated to clear, or as a single code specially identifying the pool, qualifying
entity, or series of customers, as the case may be.

(b) Orders for the Account of a Member on the Floor. Any member placing a verbal order with another floor member
for execution as a CT! #3 trade, except an order for one or more legs of a spread transaction in which the initiating
member has personally executed at least one leg of the spread, shall simultaneously either-{4) record the terms of
the order and its time of placement on his trading card in sequence with the member's other trades, as prescribed


in Rule 104.80(a}-e
. Any floor member receiving a verbal order from another floor
member for execution as a CTI #3 trade is responsible to maintain an order ticket bearing a timestamp

indicating the time of receipt of the order from the other floor member, unless such order is for electronic

execution and may immediately be entered into Globex. A floor member executing a CTI #3 trade must also

indicate in the account column of his or her trading card the alphanumeric trading acronym of the member
for whom the trade is executed.