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Chicago Mercantile Exchange
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Regulatory Advisory
TO: All Members, Clearing Member Firms, Employees and CME RA-06-02
Globex® Users (supersedes
RA-05-05)
FROM: CME Market Regulation Department
DATE: March 22, 2006

SUBJECT: Updated Requirements for Workstation Operator Identifiers on CME
Globex Orders Entered through CME iLink® Connections

CME requires that every electronic order submitted to CME Globex contain information which
identifies the workstation operator. This Advisory, which supersedes Regulatory Advisory RA-05-
05, will discuss the conventions for identifying workstation operators on orders sent in through
CME iLink connections depending upon whether the orders are entered manually, or via
automated or semi-automated means. Further, this Advisory will discuss a simplified process for
registering an Automated Trading System (“ATS”) with CME.

All market users should be aware that CME Rule 576 (“Identification of GLOBEX Terminal
Operators”) requires that terminal operators be identified to the Exchange in the manner prescribed
by the Exchange. The rule also states that ‘it is the duty of the clearing member to ensure that
registration is current and accurate at all times.”

The workstation operator identifier (also known as the senderSubID, or Tag 50) is required for all
orders entered through CME iLink connections. This identifier can be up to 18 bytes (characters)
maximum length and should be transmitted in FIX Tag 50. Accurate data in this FIX tag is
necessary for regulatory purposes, and in some circumstances is required for the proper fees to be
applied. Failure to submit accurate data, including workstation operator identifier data, into the
Exchange Fee System (“EFS”) may be a violation of Exchange Rule 576.

The following are the specific requirements depending on whether CME Globex orders are entered
by an individual terminal operator or through an ATS:

Individual Workstation Operators
For manually entered orders, the workstation operator identifier must uniquely identify the person

who entered the instruction into the system. The clearing firm that guarantees the connection point
must ensure that the workstation operator identifier used through its connection point is unique to

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CME Regulatory Advisory 06-02
March 22,2006
Page 2 of 3

that firm, and not shared with anyone else. This requirement applies to everyone, including
individual members, employees of a clearing firm, customers, or anyone else entering an order on
behalf of another party.

Regardless of whether the workstation operator identifier is registered in EFS, clearing firms must
be able to provide Market Regulation with the identity of the person assigned a particular user code
upon request, and must maintain historical records for at least five years to identify each user
code. A person should not have multiple user codes within a particular front-end system.

Automated Trading Systems

An ATS is an electronic system or computer software that is programmed to generate and send
orders into CME Globex in an automated or semi-automated fashion. An ATS controller is a
person who operates, and/or administers the ATS system. Typically this is a person who initiates
or disables particular algorithms or strategies, or adjusts the parameters of the automated program.

All ATSs that do not require an individual to initiate or manually confirm the creation of a specific
instruction must identify the workstation operator identifier by assigning a unique Tag 50 value for
each independent model, algorithm, program, and/or process under each ATS controller. If there
are multiple ATS programs/models that are administered by the same party, each should be
assigned a separate Tag 50 value. Any deviations from this requirement must be approved by
CME Market Regulation.

In the Exchange Fee System, the clearing firm should associate each ATS workstation operator
identifier with the name of the person who is directly responsible for controlling the trading of that
ATS system, and must check the box on the EFS screen to indicate that the Tag 50 represents an
ATS system. It is the responsibility of each ATS client to provide accurate and up to date
information to their clearing firm on their ATS controllers and their Tag 50 values.

Effective with the issuance of this Advisory, CME will no longer require every ATS system to file an
Automated Trading System Connection Registration form (Schedule 8). However, when
registration of TAG 50 is required in the fee system, the Clearing Firm registering the TAG 50 must
check the ATS box on the registration screen to indicate that the registration is on behalf of an
automated or semi-automated trade entry. This will replace the current process of filing registration
forms. Existing ATS systems which have previously filed a schedule 8 do not need to have their
clearing firms modify their existing registration in the fee system.

Further, if CME needs additional information on an ATS system, it may ask that the ATS operator
fill out the Automated Trading System Connection Registration form which can be downloaded at
http://www.cme.com/files/CMEGlobexSch8ATS. pdf.

Registration of Workstation Operator Identifiers (Tag 50)

While every person or ATS entering orders through CME iLink connections must be identified by a
workstation operator identifier, registration of those IDs in the Exchange Fee System is only
required for individual members and their approved clerks, employees and independent



CME Regulatory Advisory 06-02
March 22, 2006
Page 3 of 3

contractors of clearing members, and other traders or employees of trading entities which are
receiving preferential rates as a result of membership or enrollment in incentive programs. This
includes CME Rule 106.H. (“Corporate Member Firm Transfers”) members, CME Rule 106.1.
(‘Related Party Employee Transfers”) members, CME Rule 106.R. (“Electronic Corporate Member
Transfers”) members (“ECMs”), CME Rule 106.S. (“Family of Funds Transfers”) members, Asian
Incentive Program (“AIP”) participants, Emerging Market Partner Program (“EMPP”) participants,
European Incentive Program (“EIP”) participants, FX Bank Incentive Program (“BIP”) participants
and CTA/Hedge Fund Pilot Program participants. The workstation operator identifier value that is
registered in EFS must exactly match the workstation operator identifier (i.e. the Tag 50) value that
is submitted to the Exchange on orders entered through CME iLink connections.

If you have any questions relating to this Advisory please contact James Moran at 312/930.8520,
Lou Abarcar at 312/648.3623, Robert Sniegowski at 312/648.5493 or Kathy Zaino at 312/930.-
2341. Fee questions should be directed to the EFS support line at 312/648.5470.