Exhibit I

3" Quarter 2006 ITM Product Ratios

30 Yr., 10 Yr., 5 Yr., 2 Yr. U.S. Treasury Futures 10:1
30 Yr. U.S. Treasury Bond Options 50:1
10 Yr. U.S. Treasury Note Options 50:1
5 Yr., 2 Yr. U.S. Treasury Note Options 20:1
Fed Fund Futures 10:1
Fed Fund Options 20:1
Mini-Dow Futures 10:1
Mini-Dow Options 20:1
Dow Futures 20:1
Dow Options 20:1
Big Dow Futures : 10:1
Agricultural Futures and Ethanol Futures 50:1
Agricultural Options 50:1
Mini-Gold Futures 100:1
Mini-Silver Futures 50:1
Gold Futures 50:1
Gold Options 50:1
Silver Futures 50:1
Silver Options 50:1
10 Year Interest Rate Swap Futures 20:1
5 Year Interest Rate Swap Futures 50:1
10 Year Interest Rate Swap Options 20:1
5 Year Interest Rate Swap Options 20:1
Dow Jones AIG Commodity Index 50:1
Binary Options on the Target Federal Funds Rate 20:1



RECEIVED
CAEL.

August 31, 2006

Ms. Eileen A. Donovan

Acting Secretary

Commodity Futures Trading Commission
Three Lafayette Center

1155 21" Street, N.W.

Washington, D.C. 20581

Reference File # 2717.01
Rule Certification
Dear Ms. Donovan:

Pursuant to Commission Regulation 40.6(a), the Chicago Board of Trade (CBOT®) hereby
submits the following:

- FEstablishment of an e-cbot® Message Use Policy as set forth in the attached text.
The referenced policy is designed to enhance the performance of the Exchange’s e-cbot®
electronic marketplace by encouraging efficient messaging activity on the part of market
participants. After undergoing development in a pilot program format, the policy in its final
form will introduce message use surcharges as an incentive for compliance with specified
message use guidelines.

The CBOT intends to implement this policy as of September 1, 2006.

There were no opposing views concerning this policy.

The CBOT certifies that this policy complies with the Commodity Exchange Act and the rules
thereunder.

Sincerely,

Paul J. Draths
Vice President and Secretary
b081506


e-cbot® Message Use Policy
Effective September 1, 2006

Executive Summary

The CBOT® provides state-of-the-art technology to its users. The success of the e-cbot®
trading platform is due to the strong commitment from all trading Firms, Independent
Software Vendors (ISVs) and Member Developers to manage their trading activity and
dynamic pricing information. It is important that end users conform to existing order message
guidelines to ensure maximum marketplace performance.

Introduction

The CBOT is committed to providing the optimal trading experience for its users. In order to
assure integrity and efficiency in the e-cbot marketplace, the CBOT implemented its current
Message Use Policy in March 2004, The Message Use Policy of the CBOT plays an integral
part to help the entire marketplace consistently benefit from the superior execution capacity
and strategy capabilities of this dynamic system.

Message to Executed Volume Ratios
The Message Use Policy will continue to evaluate messaging activity at the Individual Trader

Mnemonic (ITM) level to isolate specific users who may negatively impact the market
through inefficient messaging.

Order messages are defined as submits, pulls and revisions to the trading host. The Product
Ratio is the number of order messages to the contract volume executed electronically. The
CBOT will publish Product Ratios for all electronically traded products (see Exhibit I).
Product Ratios will be distributed quarterly based on the previous quarter’s execution activity
and message data.

The following parameters apply per ITM:
¢ Product Ratios are applicable for daytime trading hours only (7:00 a.m. to 4:00 p.m.
Chicago time). However, the CBOT will continue to monitor evening and overnight
activity and expand time parameters if necessary.
¢ Total ITM order messages are calculated by summing all submit, pull and revise
messages by product.
¢ Total ITM volumes are calculated by summing the number of buy and sell contracts
executed by product.
© The ITM’s Product Ratio is total number of order messages allowed to be submitted
per executed contract
ITMs submitting less than 1,000 messages per product daily are exempt.
Messaging across product complexes will no longer be used.
Daily charges under $1,000 will be waived.
Product Ratio calculations and charges are calculated on a daily basis.

Exchange designated Market Makers will be subject to separate and specific messaging
guidelines.

Quarterly Product Ratios will be published via the e-cbot Bulletin and posted on the CBOT

website at www.cbot.com/messageusepolicy . Please refer to Exhibit I for the current Product
Ratios.

Reporting Methodology


Reports are generated T+1 and analyzed by the CBOT for violations. Exception reports are
reviewed daily by the CBOT Key Account Managers (KAMs) and violations are e-mailed to
the Member Firm if the policy is violated. At the end of each month, the KAM e-mails a
Monthly Threshold Exception Summary Report to the Member Firm that summarizes each
violation for the month. When excessive messaging is noted real time, the Key Account
Manager will contact the Firm or ITM Responsible Person.

Message Use Surcharges and Appeals
ITMs that exceed Product Ratio(s) will be given two exemptions per product, per calendar

month. When the final updated policy is implemented, each violation of the Message Use
Policy after the exemptions will result in a charge equal to 10¢ per message exceeding the
ITM Product Ratio (per product, per ITM) for each violation. Daily surcharges under $1,000
will be waived.

Once a Member Firm receives the Monthly Threshold Exception Summary Report, the
Member Firm may submit an appeal to the Message Use Committee if it believes the
circumstances of the event(s) have been rectified. In this situation, details of the
circumstances including preventative measures taken must be included. Requests for appeal
of charges must be sent via e-mail to the CBOT KAM and received no later than 10 days after
the Monthly Threshold Exception Summary Report has been received. Final charges will be
billed through the Primary Clearing Member via the Exchange’s Dashboard system