Exhibit A

HEDGE
Street

cc) DOLLAR MULTIPLIER ~ The Dollar Multiplier shall be 10,000.

(2) WEEKLY VARIABLE PAYOUT CONTRACT 2

aa) CAP ~ The Cap shall be X + 0.005.

bb) FLOOR ~ The Floor shall be X — 0.005.

cc) DOLLAR MULTIPLIER —~ The Dollar Multiplier shall be 10,000.

(3) WEEKLY VARIABLE PAYOUT CONTRACT 3

aa) CAP ~ The Cap shall be X + 0.01.

bb) FLOOR — The Floor shall be X.

cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10,000.

(4) In each case, “X” equals the last reported USD/CHF price, rounded to
the nearest 9-6+ 0.005, as reported in the USD/CHF foreign currency market at
SPM-EF-en the previous -business-day-beforethe immediately prior to the listing of
the Weekly Variable USD/CHF Contract issisted for trading on HedgeStreet.

(ii) — (iii) [unchanged]
(g) - (0) [unchanged]
RULES 12.6 — 12 48 [unchanged]

RULE 12.49 CURRENCY EXCHANGE USD/CAD VARIABLE PAYOUT
CONTRACTS

(a) SCOPE -These Rules shall apply to the Class of Contracts referred to as
the Currency Exchange USD/CAD (“USD/CAD”) Variable Payout Hedgelet
Contracts issued by HedgeStreet.

(b) UNDERLYING - The Underlying for this Class of Contracts is the US
the US Dollar/ Canadian Dollar, herein referred to as “USD/CAD” as quoted in US
dollars per Canadian Dollar as calculated by the Source Agency using a proprietary
algorithm which takes a sampling of prices obtained from the spot USD/CAD
foreign currency market.

(c) SOURCE AGENCY - The Source Agency is HedgeStreet.

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

(3) WEEKLY VARIABLE PAYOUT CONTRACT 3

aa) CAP — The Cap shall be X + 0.01.
bb) FLOOR ~ The Floor shall be X.

cc) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 10,000.

(4) In each case, “X” equals the last reported GBP/USD price, rounded to
the nearest 0-04 0.005, 005, as reported i in the GBP/USD foreign currency market at
PMHSFenth day -beferethe immediately prior to the listing of
the Weekly Variable GBP/USD Contract ististed for trading on HedgeStreet.

(ii) — (iii) [unchanged]
(g) - (0) [unchanged]
RULE 12.4 — [unchanged]

RULE 12.5 CURRENCY EXCHANGE USD/CHF VARIABLE PAYOUT
CONTRACTS

(a) - (e) [unchanged]

(f) PAYOUT CRITERION — The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Variable Payout Contracts are initially issued.
For the Variable Payout Hedgelet Contract, the Payout Criteria for the Contracts
will be set as follows;

GAWEEKLY VARIABLE-USD/CHE CONTRACT

(1) CAP—The-Cap-shallb +005

(2) FLOOR—Fhe Fi hali-be-X—0.0

(3) DOLLAR MULTIPLIER The Dollar Multiplier shall be 500.

(i) WEEKLY VARIABLE USD/ CHF CONTRACTS

(1) WEEKLY VARIABLE PAYOUT CONTRACT 1

aa) CAP — The Cap shall be X.
bb) FLOOR — The Floor shall be X — 0.01.

1825 S. Grant Street

Suite 500

‘San Mateo, CA 94402

Tet: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

(d) TYPE — The Type of Contract is a Variable Payout Hedgelet Contract.

(e) ISSUANCE - For each planned release by the Source Agency of the

Underlying, HedgeStreet will issue various Hedgelet Contracts, each of a different
Series. A new issuance of Hedgelet Contracts will commence no later than two (2)

business days following the Expiration Date.

(f) PAYOUT CRITERION - The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Variable Payout Contracts are initially issued.

For the Variable Payout Hedgelet Contract, the Payout Criteria for the Contracts
will be set as follows;

(i) WEEKLY VARIABLE USD/CAD CONTRACTS

(1) WEEKLY VARIABLE PAYOUT CONTRACT 1

aa) CAP ~ The Cap shall be X.
bb) FLOOR — The Floor shall be X — 0.01.

cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10,000.

(2) VARIABLE PAYOUT CONTRACT 2

aa) CAP ~ The Cap shall be X + 0.005.

bb) FLOOR — The Floor shall be X - 0.005.
cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10,000.
(3) VARIABLE PAYOUT CONTRACT 3

aa) CAP — The Cap shall be X + 0.01.
bb) FLOOR —~ The Floor shall be X.

cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10,000.

(4) In each case, “X” equals the last reported USD/CAD price, rounded to
the nearest 0.005, as reported in the USD/CAD foreign currency market
immediately prior to the listing of the Weekly Variable USD/CAD Contract for
trading on HedgeStreet.

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street

vert esp 5 PU 3 56

OFC. GF THE SECRETARIAL

February 5, 2007

VIA EMAIL: secretary@cftc.gov

Ms. Eileen A. Donovan, Acting Secretary
Secretary of the Commission
Commodity Futures Trading Commission
3 Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Rule Certification: HedgeStreet® a) Amends the Weekly Payout Criteria for
both the Currency Exchange GBP/USD Variable Payout Contracts and the
Currency Exchange USD/CHF Variable Payout Contracts; and b) files new
Terms and Conditions for the Currency Exchange USD/CAD Variable
Payout Contracts — Submission pursuant to Commission Regulation §40.2
and §40.6

Dear Acting Secretary Donovan:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and
§40.2 and §40.6(a) of the regulations promulgated by the Commodity Futures Trading
Commission (the “Commission”) under the Act, HedgeStreet, Inc. (“HedgeStreet”) hereby
certifies with the Commission its intent to a) amend the Payout Criteria for both its
Currency Exchange GBP/USD Variable Payout Contracts and its Currency Exchange
USD/CHF Variable Payout Contracts. HedgeStreet also submits to the Commission b) the
terms and conditions for its new Currency Exchange USD/CAD Variable Payout Contracts;
[the underlined Contracts referenced in (a)-(b) will be collectively known as the
“Contracts”]. All corresponding rule additions/ amendments to the above-referenced
Contracts are defined in Exhibit A in accordance with Commission Regulation §40.6. Any
tule deletions are stricken out while the amendments and/or additions are underlined.
HedgeStreet has also included under Exhibit A new HedgeStreet Rule 12.49 to reflect all of
the terms and conditions of the new Currency Exchange USD/CAD Variable Payout
Contracts.

HedgeStreet intends to implement the corresponding rule additions/ amendments to all
Contracts referenced above at the start of business on Tuesday, February 6, 2007.

No substantive opposing views were expressed to HedgeStreet with respect to these
amendments.

1825 S. Grant Street
Suite 500
San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501



- Exhibit A

HEDGE
Street

(ii) HedgeStreet may list additional Variable Payout Hedgelet
Contracts with different ranges of Payout Criteria on a discretionary basis in
accordance with the CEA and Commission Regulations.

(g) MINIMUM TICK — The Minimum Tick size for USD/CAD Variable
Payout Hedgelets shall be $0.01.

(h) REPORTING LEVEL ~ The Reporting Level for the USD/CAD
Variable Payout Hedgelets shall be 12,500 Contracts.

(i) POSITION LIMIT - There are currently no Position Limits for
USD/CAD Variable Payout Hedgelets.

(j) LAST TRADING DATE - The Last Trading Date in a Series is the
same date as the Settlement Date.

(k) SETTLEMENT DATE -— The Settlement Date of the Contract shall be
the same date as the Expiration Date.

(l) EXPIRATION DATE — The Expiration Date of the Contract shall be the
date on which the USD/CAD Expiration Value is released by the Source Agency.

(m) SETTLEMENT VALUE -— The Settlement Value is the amount paid to
the holder of either a Short or Long Variable Payout Contract on Settlement Date.
The Settlement Value of a Variable Payout Hedgelet Contract is determined as
described in the definition for Long and Short Variable Payout Hedgelet Contracts.

(n) EXPIRATION VALUE — The Expiration Value is the price or value
of USD/CAD released by the Source Agency on the Expiration Date.

(0) CONTINGENCIES ~ If no level is actually announced on the
Expiration Date due to a delay, postponement or otherwise in such release
announcement by the Source Agency, the Settlement Date will be delayed until the
Underlying number is released for that Series.

[End Rulebook]

[The remainder of this page is intended to be blank]

1825 S. Grant Street
Suite $00

San Mateo, CA 94402
Tel: 650.638.3500

www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street

HedgeStreet hereby certifies that the Contracts and clearing of the Contracts, including all
rules defining the terms and conditions of said Contracts contained herein, complies with
the Act, as amended, and the Commission’s regulations adopted thereunder.

Should you have any questions regarding the above, please do not hesitate to contact
Stephanie Ford by telephone at (650) 638-3511 or by email at sford@hedgestreet.com.

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

ce: Tom Leahy - CFTC
Phil Colling — CFTC
Clarissa Manansala — HedgeStreet , Inc.

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street

EXHIBIT A

Amendments to Rules 12.3 and 12.5 and the addition of new Rule 12.49
(The following new Rule additions are underlined and deletions are stricken out)

RULES 12.1-12.2 [unchanged]

RULE 12.3 CURRENCY EXCHANGE GBP/USD VARIABLE PAYOUT
CONTRACTS

(a) - (e) [unchanged]

(f) PAYOUT CRITERION -— The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Variable Payout Contracts are initially issued.
For the Variable Payout Hedgelet Contract, the Payout Criteria for the Contracts
will be set as follows;

G)-WEEKLY VARIABLE GBPLUSD CONTRACT
(1) GCAP—Fhe-Cap-shall be X+0.05-

(2) FLOOR—The #1 hall-be-X—0-0:

(3) DOLLAR-MULTIPLIER—The Dollar Multiplier shall be 500.

(i) WEEKLY VARIABLE GBP/USD CONTRACTS

(1) WEEKLY VARIABLE PAYOUT CONTRACT 1
aa) CAP — The Cap shall be X.

bb) FLOOR ~ The Floor shall be X — 0.01.

cc) DOLLAR MULTIPLIER ~ The Dollar Multiplier shall be 10,000.
(2) WEEKLY VARIABLE PAYOUT CONTRACT 2

aa) CAP — The Cap shall be X + 0.005.

bb) FLOOR — The Floor shall be X — 0.005.
cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10,000.

1825 S. Grant Street
Suite 500
San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501