July 26, 2006 SET 83 mr er gg

Ms. Eileen A. Donovan

Acting Secretary

Commodity Futures Trading Commission
Three Lafayette Center -
1155 21" Street, N.W.

Washington, D.C. 20581

Pee Seu START AI

Reference File #2709.01
Rule Certification

Dear Ms. Donovan:

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

- Amendments to Regulation 9B.07 as indicated in the attached texts (additions
underlined; deletions bracketed).

Regulation 9B.07 governs access to e-cbot®, the Exchange’s electronic trading platform, from
the CBOT Exchange Floor. Under the current regulation, members on the Exchange Floor may
enter orders into e-cbot only for products within the scope of their particular membership
privileges. The revised regulation will permit such members to enter e-cbot orders for their own
accounts, or for proprietary accounts which they control, in any products traded on the electronic
platform. As a result of this change, members’ permissible e-cbot order entry in this regard will
be the same whether they are on the Exchange Floor or elsewhere.

The CBOT intends to implement these amendments as of September 18, 2006.

When the CBOT Board of Directors considered these amendments, two directors voted against
them (versus fifteen who voted in favor). The opponents expressed concern that the revised
provision might result in reduced participation, and thus diminish liquidity, in the open auction

market.

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

Sincerely,

Paul J. Draths
Vice President and Secretary

b071806


Revised Regulation 9B.07
Delete current Regulation, as indicated below, in its entirety:

[e-cbot Access from the Trading Floor - Individual members on the trading floor may directly
enter e-cbot orders in such products as their membership category permits. Non-member
employees of a member firm who do not maintain an associated person registration may enter e-
cbot orders on a non-discretionary basis from terminals located within the member firm’s booth
space. A non-member employee of an individual member may enter non-discretionary e-cbot
orders from within a pit solely for the account of his employing member.]

Add new Regulation 9B.07 as follows:

e-cbot Access from the Trading Floor - A member on the trading floor may directly enter e-cbot
orders for his personal account, or for a proprietary account he controls, in any product listed for
trading on e-cbot._ A member on the trading floor may directly enter e-cbot orders for accounts
other than his own account or an account that he controls, only in such products as his

membership category permits.

A non-member employee of a member or member firm may enter e-cbot orders on a non-
discretionary basis in any product for the account of his employer, but may enter orders for the
accounts of others only in those products consistent with his employer’s membership privileges.
Orders entered by a non-member employee on behalf of an account other than his employer’s
account may be entered from within a trading pit only at the specific direction of the floor broker
who employs the non-member clerk.

The permissible locations of clerks within a trading pit shall be subject to the discretion of the
relevant Pit Committee and the permissible locations of clerks outside of the trading pit shall be
subject to the discretion of the Exchange.