Reportable Options Level-Reportable options position in any one month in each option category.
Note:0ption categories are long call, long put, short call, and short put.

Net Equivalent Futures Position-Each option contract will be adjusted by the prior day's risk factor, or
delta coefficient, for that option which has been calculated by the Exchange’s Clearing Services Provider

For the purpose of this Appendix:

(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 Exchange’s Clearing Services Provider. For example, 8 tong 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 product in which the sum of the delta factors is zero.

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

“SPOT | “SINGLE ) TALL *REPORTABLE | REPORTABLE

CONTRACT MONTH MONTH MONTH FUTURES OPTIONS |

LEVEL LEVEL |
Credit Default Swap None None None 200 |
Index Futures | |



June 4, 2007 Teel pt mag

Ms. Eileen A. Donovan

Acting Secretary

Commodity Futures Trading Commission
Three Lafayette Center

1155 21* Street, N.W.

Washington, D.C. 20581

Reference File # 2796.01
Rule Certification
Dear Ms. Donovan:

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

- Amendments to Regulations 290.03, 331.08, 425.06 and CBOT Rulebook Appendix
AC per the attached texts (additions in boldface and underlined; deletions in bold
face and struck through).

With respect to CBOT Credit Default Swap (“CDS”) Index futures, the referenced amendments
will codify the following:

- In Regulation 290.03, designation in the “IDEM” market category,
- In Regulation 331.08, eligibility for “Exchange of Futures for Related Transactions”;
- In Regulation 425.06, position accountability; and

- In Rulebook Appendix 4C (incorporated by reference into Regulation 425.01),
position limits and reportable position levels.

The CBOT intends to implement these amendments concurrently with the launch of trading in
CBOT CDS Index futures (presently scheduled for trade date June 25, 2007).

There were no opposing views 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
b051507


290.03 Index, Debt and Energy Market (IDEM)- The IDEM consists of the following futures
contracts: 30-Day Fed Fund, Portfolios (when designated), Stock Indexes, CBOT® Dow Jones-AIG
Commodity IndexTM, CBOT® Dow Jones-AIG Excess Return Commodity IndexTM", CBOT® X-Fund,
Corporate Bond Index, Commercial Paper (30 days), Commercial Paper (90 days), Municipal Bonds
(when designated), 10-Year Municipal Note Index, Municipal Bond Index, Eurodollars, Crude Oil (when
designated), Leaded Gasoline (when designated), Unleaded Gasoline (when designated), Heating Oil
(when designated), Silver, Gold, Gold Coins (when designated) Plywood, Structural Panel Index, CBOT
U.S. Dollar Composite Index, CBOT Argentina, Brazil and Mexico Brady Bond Indexes, U.S. Treasury
Yield Curve Spread, ComEdTM, TVA Hub Electricity,-and CBOT® Dow JonesTM US Real Estate Index, and
Credit Default Swap Index.

331.08 Exchange of Futures for Related Transactions

(a) The following transactions may be executed outside of the Exchange’s central markets, in accordance
with the requirements of this Regulation.

(i) Exchanges of futures for, or in connection with, cash commodities (“Exchange for Physical
Transactions” or “EFPs”). EFPs may be executed in all CBOT futures contracts.

(ii) Exchanges of futures for, or in connection with, swap transactions (“Exchange for Swap
Transactions” or “EFSs”). EFSs may be executed only in U.S. Treasury Bond futures; Long
Term, Medium Term. and Short Term U.S. Treasury Note Futures; CBOT Dow Jones-AIG Excess
Return Commodity Index*” Futures; and-30-Year, 10-Year and 5-Year Interest Rate Swap
Futures; and Credit Default Swap Index Futures.

(iii) Exchanges of futures for, or in connection with, over-the-counter derivates (“OTC”)
transactions (“Exchange for Risk Transactions” or “EFRs”). EFRs may be executed only in CBOT
agricultural commodity futures and in U.S. Treasury Bond Futures; Long Term, Medium Term,
and Short Term U.S. Treasury Note Futures; CBOT Dow Jones-AlG Excess Return Commodity
Index®” Futures; 30-Day Fed Fund Futures; and-30-Year, 10-Year, and 5-Year Interest Rate
Swap Futures; and Credit Default Swap Index Futures. The OTC component of an EFR must
comply with any applicable regulatory requirements prescribed by the Commodity Futures
Trading Commission.

(iv) Options on futures are not a permissible component of an EFP, EFS or EFR.

For purposes of this Regulation, all EFPs, EFSs and EFRs shall be referred to as Exchanges of Futures
for Related Positions.

425.06 Position Accountability - A person, as defined in Regulation 425.01(a)(i), who holds or
controls, or a member firm that carries for another person, aggregate positions in excess of those
specified in the chart below, shall be subject to the following provisions:

- Such person shall provide, in a timely manner upon request by the Exchange, information regarding
the nature of the position, trading strategy, and hedging information if applicable.

- Such person shall be deemed to have consented, when so ordered by the Exchange acting in its
discretion, not to further increase the positions which exceed the levels specified in the chart below.

- Such positions must be initiated and liquidated in an orderly manner.


For purposes of this regulation, all positions in accounts for which a person, by power of attorney or
otherwise, directly or indirectly controls trading shall be included with the positions held by such person.
The provisions of this regulation 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.

Nothing herein shall limit the jurisdiction of the Exchange.

CONTRACT ‘SPOT MONTH* [ALL MONTHS** (OPTIONS***
US Treasury Bonds 110,000 [10,000 25,000
10-Yr. Treasury Notes '7,500 17,500 (20,000
5-Yr. Treasury Notes (7,500 17,500 120,000
2-Yr. Treasury Notes 17,500 [7,500 20,000
30-Day Fed Funds 8,000 13,000

Binary Options on the Fed | 3,000
30-Yr. Interest Rate Swap 15,000 5,000

'10-Yr. Interest Rate Swap 5,000 15,000
5-Yr. Interest Rate Swap 5,000 15,000
Credit Default Swap Index 500

* All numbers refer to futures contracts, and/or futures-equivalent contracts, net long or net short, in the
spot month.

“* All numbers refer to futures contracts, and/or futures-equivalent contracts, net long or net short in all
months and strike prices combined. Net equivalent futures positions shall be determined in the same
manner specified in Appendix 4C.

**All numbers refer to option contracts for all months and all strike prices combined in each option
category (long call, long put, short call, and short put). (03/19/07)

Appendix 4C

Position Limits and Reportable Positions
The following are definitions of titles used in the position limit chart contained in this Appendix -

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-equivatent position limit net long or net short in any one month other than the spot
month.

All Months -Position limit net tong 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-equivaients 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.