execution discussions to participate in the transaction in accordance with this
policy and the order or quote is entered to implement that agreement; and

3. Except for block trades conducted pursuant to Rule 417 and exchange of
future for physical transactions conducted pursuant to Rule 416, a period of
four seconds shall elapse between entering the first order or quote and
entering the second order for the opposite side. The order or quote initially
entered may be filled or lifted by a third party during the four-second waiting
period rather than consummating the transaction with the intended party as
contemplated by the pre-execution discussions.

Cross Trades

In accordance with OneChicago Rules 409 and 610, a Member may cross orders,
provided that the Member enters one side of the trade (which shall be the Customer’s side
in the event that the Member or its affiliate is taking the other side) into OneChicago’s
trading system at least four seconds before entering the order for the opposite side.


OOM HelpDesk Report in a form and method approved by OneChicago. In case of a
phoned in trade report, bBoth sides must include the Trade ID given by the OOM Help
Desk to the seller at the time of his call. It is the responsibility of the buying and selling
firms to effect any subsequent allocations or necessary updates to non-critical matching
fields utilizing their chosen post-trade processing system.

To protect market integrity during the negotiation and reporting period, any party with
knowledge of the pending block trade is prohibited from entering offsetting orders in the
specific or any related OneChicago product for the benefit of the account or accounts
related to a party to the block trade until the block trade has been reported to and
disseminated by GFN the OneChicago price distribution mechanism. Additionally, no
party with knowledge of the pending block trade report is allowed to exercise discretion
by withholding (or placing) orders for any account that would have (or would not have)
been placed given but for the knowledge of the pending block trade until the block trade
has been reported to and disseminated by the GEN the OneChicago price distribution
mechanism. Parties subject to the jurisdiction of a member or an affiliate of

the Intermarket Surveillance Group (“ISG”) are further prohibited from submitting
related offsetting orders on OneChicago if they utilize block trade reporting facilities of
any other ISG participant exchange until such trades have been disseminated to the
marketplace via the standard public reporting mechanism for that exchange.

OneChicago considers busting block trades to be a serious matter and may deny a bust
request based on the factors surrounding the request, including but not limited to the
market impact of the original report, the amount of variation between the block trade
price and the market price at the time of the report and the length of time transpiring
since the block trade was reported to the public. Fees wil may be levied for busting a
block trade.

Any attempt to circumvent this policy or misrepresent a transaction as a block trade will
be forwarded to the appropriate party for investigation.

Pre-Execution Discussions

In accordance with OneChicago Rule 614, the Exchange permits Members and Access
Persons to engage in pre-execution discussions pursuant to which one party may agree in
advance to take the opposite side of the other party’s order for a transaction to be
executed on the Exchange, on the following conditions:

1. Customers of each such party must consent to allow pre-execution discussions
with other market participants;

2. Any Member or Access Person who is solicited to participate in a OneChicago
transaction through pre-execution discussions shall not (i) disclose to any
other party the details of such discussions or (ii) enter an order or quote
through the Exchange to take advantage of information conveyed during such
discussions unless such Member or Access Person has agreed during the pre-



ts Office of In-House Counsel, LLC ca; cro -5 TT

Madge M. Piro a
1300 Pennsylvania Avenue, N.W. °
Suite 700

Washington, DC 20004

202.204.3088

Fax: 202.318.9105

piro@oic-trading.com

September 5, 2006

Ms. Eileen A. Donovan

Secretary

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: — Security Futures Products Rule Submission and Rule Certification

Dear Ms. Donovan:

On behalf of my client, OneChicago, LLC, and pursuant to section
Se(c)(1) of the Commodity Exchange Act, as amended (the “Act”), and section 41.24 of
the regulations promulgated by the Commission under the Act, submitted herewith is a
rule amendment to the OneChicago, LLC (“‘OneChicago”) “Policies: Block Trades, Pre-
Execution Discussions and Cross Trades” (“Block Trade Policy”). The rule amendment
will be effective on September 8, 2006.

OneChicago is amending its Block Trade Policy to reduce the minimum
contract size from 500 to 100; to clarify that block trades must be executed no earlier than
one-half hour before the opening and no later than one-half after the close of the trading
session; to incorporate language from OneChicago Rule 417; to permit members to report
their block trades in a form and method approved by the Exchange; to clarify that a

Practice Limited to Federal Securities and Commodity Futures Law
Not licensed in DC
Member of the Bars of the State of Michigan and State of Illinois


combination of trades may be necessary to achieve a specific price differential for an
overall trade event and for these trades that information must be provided to link the
telated legs of the block trade event; and other non-substantive changes.

There are no opposing views that are not incorporated into this rule
amendment.

On behalf of OneChicago, I hereby certify that that the amendment to the
initial listing standard for single stock futures complies with the Act and regulations
promulgated thereunder.

/s/__Madge M. Piro
Madge M. Piro
Office of In-House Counsel, LLC



Appendix A

OneChicago Policies:
Block Trades, Pre-Execution Discussions and Cross Trades

Block Trades

Pursuant to OneChicago Rule 417, the Exchange permits eligible contract participants,
see Rule 417(a), to execute block trades away from the public auction market in privately
negotiated transactions for a minimum of 509 100 contracts per transaction. All block
trades must be executed no earlier than one-half hour before trading begins in the
Contract of the block trade on the Business Day of execution and no later than one-half
hour after trading ends in the Contract of the block trade on the Business Day of
execution.

Each firm executing a side of a block trade must have at least one designated person
preauthorized to report block trades. Only OneChicago member firms with a clearing
relationship at The Options Clearing Corporation or the Chicago Mercantile Exchange
Clearing Division will be allowed to report a block trade.

All block trades must _be reported to OneChicago without delay after the trade is executed
and must include the basic terms of the trade, including the relevant Contract, contract
month, price,’ quantity, time of execution, counterparty clearing member for each block
trade and, if applicable, the underlying commodity. Except for electronically generated
forms, tFhe seller is obligated to call OneChicago Operations Management (“OOM”)
Help Desk without delay after the trade is negotiated to notify the Exchange of the basic
terms of the trade, including the Ceontract, contract month, price, quantity, time of
execution and contra-party information. If the transaction is a spread or combination,
such as when one party is rolling a position into the next contract month, the seller of
the month closest to expiration is responsible for reporting the entire transaction. In the
case of phoned in reports, the OOM Help Desk will provide the caller a Trade
Identification (“Trade ID”) for the block trade, and After the parties have reported a
block trade, the OOM Help Desk will report both sides of the trade to the OneChicago
trade engine. The trade engine will then relay the block trade terms to the Ghicage-Board
Opti Exch. ial Network CEN) which the OneChicago price
distribution nee and OneChicago’ Ss matched trade database.

After reporting the tradeto-OOM In all cases, the buyer and seller must each complete
and transmit the-preseribed a Block Trade Reporting form-yiafe th

In some cases a combination of trades may be necessary to achieve a specific price differential for the
overall trade event. In these cases, sufficient information must be provided to link related legs to the
block trade event,

For purposes of this policy, regardless of the type of form used to report the trade, the total quantity
of the legs of a spread or a combination must meet the 500 minimum contracts requirement.