[Wheat and 600 3,000 4,000 150 150
ICBOT mini-sized Wheat (aggregate, |(aggregate| (aggregate, (individual,
see #8, 10)| , see #1, |see #1, 7, 10) see #11)
10) oe
‘Oats : 600 1,000 1,500 60 60
(see#1) | (see#1,6) __
Rough Rice 600 1,000 1,000 50 50
_ _(see#5) | (see#2)
Soybean Oil 540 3,000 4,000 200 200
_ (see#1,7) | (see#1,7)

Soybean Meal 720 3,000 4,000 200 200

(see#1,7) | (see#1,7)
Ethanol _ 200 1,000 1,000 | 25

#1 Additional futures contracts may be heid outside of the spot month as part of futures/futures spreads
within a crop year provided that the total of such positions, when combined with outright positions, do not
exceed the all months combined limit. In addition, a person may own or control additional options in
excess of the futures-equivalent limits provided that those option contracts in excess of the futures-
equivalent limits are part of an eligible option/futures spread.

#2 No more than 500 futures-equivalent contracts net on the same side of the market are allowed in a
single month in all strike prices combined. Additional options contracts may be held as part of
option/options or option/futures spreads between months within the same crop year provided that the total
of such positions, when combined with outright positions, does not exceed the all months combined limit.
The futures-equivalents for both the options and futures contracts are aggregated to determine
compliance with these net same side single month position limits.

#3 No more than 5,500 futures-equivalent contracts net on the same side of the market are allowed in a
single month in all strike prices combined. Additional options contracts may be held as part of
option/option or option/futures spreads between months within the same crop year provided that the total
of such positions, when combined with outright positions, does not exceed the all months combined limit.
The futures-equivalents for both the options and futures contracts are aggregated to determine
compliance with these net same side single month position limits.

#4 No more than 3,500 futures-equivalent contracts net on the same side of the market are allowed in a
single month in all strike prices combined. Additional options contracts may be held as part of
option/option or option/futures spreads between months within the same crop year provided that the total
of such positions, when combined with outright positions, does not exceed the all months combined limit.
The futures-equivalents for both the options and futures contracts are aggregated to determined
compliance with these net same side single month position limits.

#5 In the last five trading days of the expiring futures month, the speculative position limit for the July
futures month will be 200 contracts and for the September futures month the limit will be 250 contracts.

#6 No more than 1,000 futures-equivalent contracts net on the same side of the market are allowed in a
single month in all strike prices combined. Additional options contracts may be held as part of
option/option or option/futures spreads between months within the same crop year provided that the total
of such positions, when combined with outright positions, does not exceed the all months combined limit.
The futures-equivalents for both the options and futures contracts are aggregated to determined
compliance with these net same side single month position limits.

#7 No more than 3,000 futures-equivalent contracts net on the same side of the market are allowed in a
single month in all strike prices combined. Additional options contracts may be held as part of
option/option or option/futures spreads between months within the same crop year provided that the total



*SPOT |*SINGLE| *ALL |*REPORTABLE | *REPORTABLE
ICONTRACT MONTH | MONTH; MONTH FUTURES OPTIONS
a LEVEL LEVEL
(Bund None _None None 1,000
Bobi None None None 800
Schatz None None None | 500
10-Year Interest Rate Swap _ None None None 500 500
|5-Year Interest Rate Swap None None None 500 500
ICBOT Dow Jones Industrial None None 50,000 200 200
Average” Index ' (aggregate
| DJIATM limit,
_ sec #9)
ICBOT mini-sized DowTM ($5 None None 50,000 200 200
multiplier) (aggregate
DJIATM limit,
__ _ see #9)
ICBOT Dow Jones-AIG None None 15,000 25
Commodity
Index®TM” _ .
ICBOT 5,000 oz. Silver 1,500__| 6,000 6,000 _ 150 _
ICBOT 100 oz. Gold 3,000 6,000 6,000 200
ICBOT mini-sized Silver 1,500 1,500 3,000 750
ICBOT mini-sized Gold i 4,000 4,000 | 6,000 _ 600
U.S. Treasury Bonds ; [None] None. | None 1,500 1,500
__ | See #13 |
Imini-sized U.S. Treasury Bonds} _ None None | _ None 1,500
U.S. Treasury Notes (Syr.) [None] None None 2,000 2,000
_ | See #13
U.S. Treasury Notes (6 1/2- [None] None None 2,000 2,000
WOyr.) See #13 |
U.S. Treasury Notes (2yr.) [None] None None 1,000 1,000
See #13
30 Day Fed Fund __ None None None _ 600 600
10-Year Municipal Note Index 5,000 None 5,000 _ 300
imini-sized Eurodollars 10,000 10,000 10,000 400
Corn and CBOT mini-sized 600 5,500 9,000 250 250
Corn (aggregate, |(aggregate| (aggregate, (individual,
see #10) | , see #1, |see #1, 3, 10) see #11)
10)
Soybeans and 600 3,500 5,500 150 150
(CBOT mini-sized Soybeans (aggregate, |(aggregate| (aggregate, (individual,
see #10) | , see #1, |see #1, 4, 10) see #11)
a 10) |
South American Soybeans 600 3,500 5,500 150
(see #12) | (see #1) (see #1)



of such positions, when combined with outright positions, does not exceed the all months combined limit.
The futures-equivalents for both the options and futures contracts are aggregated to determine
compliance with these net same side single month position limits.

#8 In the last five trading days of the expiring futures month in May, the speculative position limit will be
600 contracts if deliverable supplies are at or above 2,400 contracts, 500 contracts if deliverable supplies
are between 2,000 and 2,399 contracts, 400 contracts if deliverable supplies are between 1,600 and
1,999 contracts, 300 contracts if deliverable supplies are between 1,200 and 1,599 contracts, and 220
contracts if deliverable supplies are below 1,200 contracts. Deliverable supplies will be determined from
the CBOT’s Stocks of Grain report on the Friday preceding the first notice day for the May contract month.
For the purposes of these regulations, one mini-sized Wheat contract shall be deemed to be equivalent to
one-fifth of a corresponding Wheat contract.

#9 The aggregate position limit in CBOT mini-sized DowTM ($5 multiplier) futures and CBOT DJIA®”
futures and options is 50,000 DJIA*” contracts, net long or net short in all contract months combined. For
the purposes of these regulations, one mini-sized Dow TM ($5 multiplier) contract shall be deemed to be
equivalent to one-half of a DJIATM futures contract.

#10 The net long or net short positions in Corn, Soybeans, or Wheat contracts may not exceed their
respective position limits. The net long or net short positions in mini-sized Corn, mini-sized Soybeans, or
mini-sized Wheat contracts may not exceed their respective position limits. The aggregate net long or net
short positions in Corn and mini-sized Corn, Soybeans and mini-sized Soybeans, or Wheat and mini-
sized Wheat contracts may not exceed their respective position limits. For the purposes of these
regulations, one mini-sized Corn, one mini-sized Soybeans, or one mini-sized Wheat contract shall be
deemed to be equivalent to one-fifth of a corresponding Corn, Soybeans, or Wheat contract.

#11 The reporting level for the primary contract is separate from the reporting level for the mini-sized
contract. Positions in any one month at or above the contract level indicated trigger reportable status.
For a person in reportable status, all positions in any month of that contract must be reported. For the
purposes of these regulations, positions are on a contract basis.

#12 In the last five trading days of the expiring futures month, the speculative position limit for the
November futures month will be 180 contracts and the January futures month the speculative position
limit will be 365 contracts.

#13 In the last ten trading days of the expiring futures month, the following position limits in the expiring
contract will apply: U.S. Treasury Bonds — 25,000 contracts; U.S. Treasury Notes (6 % — 10 Yr.) — 50,000
contracts; U.S. Treasury Notes (5 Yr.) — 35,000 contracts; U.S. Treasury Notes (2 Yr.) — 25,000 contracts.
No hedge exemptions will be permitted with respect to these limits. The position limits noted herein shall
apply beginning with the December 2005 Treasury futures contracts.

Except for the interest of a limited partner or shareholder (other than the commodity pool operator) in a
commodity pool, ownership, including a 10% or more financial ownership interest, shall constitute control
over an account except as provided in Regulation 425.05.

The maximum positions which any person, as defined in Regulation 425.01 (c), may own or control shall
be as set forth herein. However, with respect to the maximum positions which a member firm may carry
for its customers, it shall not be a violation of the limits set forth herein to carry customer positions in
excess of such limits for such reasonable period of time as the firm may require to discover and liquidate
the excess positions or file the appropriate hedge or exemption statements for the customer accounts in
question in accordance with Regulations 425.03 and 425.04. For the purposes of this regulation, a
“reasonable period of time” shall generally not exceed one business day for those positions that are not
subject to the provisions of Regulations 425.03 and 425.04.

However, for any option position that exceeds position limits for passive reasons such as a market move
or exercise assignment, the person shall be allowed one business day to liquidate the excess position
without being considered in violation of the limits. In addition, if at the close of trading, an option position
exceeds position limits when evaluated using the previous day’s delta factors, but does not exceed the
limits when evaluated using the delta factors for that day's close of trading, then the position shall not
constitute a position limit violation.


June 28, 2005

Ms. Jean A. Webb

Secretary

Commodity Futures Trading Commission
Three Lafayette Center

1155 21" Street, N.W.

Washington, D.C. 20581

Reference File # 2563.01
Rule Certification
Dear Ms. Webb:

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

- Amendments to Regulation 425.01 per the attached text (additions underlined;
deletions bracketed).

These amendments will establish position limits, without hedge exemptions, during the last ten
trading days of each of the following CBOT Treasury futures: U.S. Treasury Bonds, 10-Year
Treasury Notes, 5-Year Treasury Notes and 2-Year Treasury Notes.

The CBOT intends to implement these amendments beginning with the December 2005 contract
month for each of the respective futures.

There were no opposing views among the CBOT Board of Directors concerning these
amendments.

The CBOT certifies that these amendments comply with the Commodity Exchange Act and the
tules thereunder.

Sincerely,

Paul J. Draths
Vice President and Secretary

B062105


Note: The Commodity Futures Trading Commission has imposed speculative position limits on Corn,
Oats, Soybean, Wheat, Soybean Oil and Soybean Meal futures contracts as provided in Part 150 of
CFTC Regulations.

(c)

(d)

(e)

()

(9)

The term “net” shall mean the long or short position held after offsetting long futures positions against
short futures positions. The word "person" shall include individuals, associations, partnerships, limited
liability companies, corporations and trusts.

The foregoing limits on positions shall not apply to bona fide hedging positions which meet the
requirements of Regulations 425.02 and 425.03, nor to positions subject to particular limits granted
pursuant to Regulation 425.04.

The Board, or a Committee authorized by the Board may direct any member or registered eligible
business organization owning, controlling or carrying a position for a person whose total position as
defined in subsection (f) below exceeds the position limits as set forth in subsection (b) above or as
specifically determined pursuant to Regulations 425.03 or 425.04 to liquidate or otherwise reduce the
position.

In determining whether any person has exceeded the position limits specified in subsection (b) of this
Regulation or those limits determined pursuant to Regulations 425.03 or 425.04, or whether a position
is a reportable position as set forth in subsections (b) and (g) herein, all positions in accounts for which
such person by power of attorney or otherwise directly or indirectly controls trading, except as provided
in Regulation 425.05, shall be included with the positions held by such person. Such limits upon
positions shall apply to positions held by two or more persons acting pursuant to an expressed or
implied agreement or understanding, the same as if the positions were held by a single person.

If a person owns, controls or carries a position equal to or greater than the number of contracts
specified in subsection (b) above long or short in any one month, then all such futures and options on
such futures contract owned, controlled or carried by that person, whether above the given level or not,
shall necessarily be deemed reportable positions. Every member or registered eligible business
organization shall report each and every reportable position to the Office of Investigations and Audits
at such times and in such form and manner as shall be prescribed by the Business Conduct
Committee.

(1) On or before the first day on which any position must be reported as provided above, the member
or registered eligible business organization carrying the position must furnish to the Office of
Investigations and Audits a report, in the form, manner and content prescribed by the Business
Conduct Committee, identifying the owner of the account for which the position must be reported
and all persons associated with the account as described in subsection (f) above.

(2) | Every member or registered eligible business organization must report each and every reportable
position and provide the report required in subsection (1) above for each person within any
account carried on an omnibus basis, unless, upon application of the member or registered eligible
business organization to the Business Conduct Committee, the nonmember omnibus account
specifically is approved to report directly to the Office of Investigations and Audits. (05/01/05)


Ch4 Position Limits and Reportable Positions
425.01 Position Limits -

(a) For the purposes of this Regulation, the following are definitions of titles used in position
limit chart-

Spot Month- Spot month futures-equivalent position limit net long or net short effective at
the start of trading on the first business day prior to the first trading day of the spot month.

Single Month- Futures-equivalent position limit net long or net short in any one month other
than the spot month.

All Months -Position limit net long or net short in all months and all strike prices combined.
Note: Long futures contracts, long call options, and short put options are considered to be on
the long side of the market while short futures contracts, long put options, and short call
options are considered to be on the short side of the market. For each commodity, the
futures-equivalents for both the options and futures contracts are aggregated to determine
compliance with the net long or net short same side position limits.

Reportable Futures Level-Reportable futures position in any one month.

Reportable Options Level-Reportable options position in any one month in each option
category. Note:Option categories are long call, long put, short call, and short put.

Net Equivalent Futures Position-Each option contract has been adjusted by the prior day’s
risk factor, or delta coefficient, for that option which has been calculated by the Board of
Trade Clearing Corporation.

For the purpose of this Regulation:

(i) _An option contract's futures-equivalency shall be based on the prior day's delta factor
for the option series, as published by the Board of Trade Clearing Corporation. For
example, 8 long put contracts, each with a delta factor of 0.5, would equal 4 futures-

equivalent short contracts.

(ii) Long futures contracts shall have a delta factor of +1, and short futures contracts shall
have a delta factor of -1.

(iii) Long call options and short put options shall have positive delta factors.
(iv) Short call options and long put options shall have negative delta factors.
(v) An eligible option/option or option/futures spread is defined as an intra-month or

inter-month position in the same Chicago Board of Trade commodity in which the
sum of the delta factors is zero.


(b) Except as provided in Regulations 425.03, 425.04 and 425.05, the maximum positions which
any person may own, control, or carry are as follows:

(Note: All position limits and reportable positions are in number of contracts and are based on futures
or *Net Equivalent Futures Positions.

*Please see section (a) of this Regulation for definition.