May 18, 2007 PQOY TA S2eeE

Ms. Eileen A. Donovan

Acting Secretary

Commodity Futures Trading Commission
Three Lafayette Center

1155 21* Street, N.W.

Washington, D.C. 20581

Reference File # 2791.01
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 3204.01 per the attached text (additions bolded and
underlined; deletions bracketed and struck through).

The referenced amendments will modify the strike price listing array for CBOT Soybean Oil
Options. Regulation 3204.01 currently specifies that the following strike prices are listed in the
“first tier”: a strike price closest to the previous day’s settlement price of the underlying soybean
oil futures contract, and a consecutive series of strike prices within 5.5 cents above and below
that strike. This language results in a minimum of 23 strike prices being listed for each option
contract month.

Under the referenced amendments, a strike price closest to the settlement price for the underlying
future would be listed, along with the next five consecutive higher and the next five consecutive
lower strikes. This change would result in a reduction in the minimum number of strike prices
listed from 23 to 11.

The revised strike price provision is comparable to the provisions current in effect for CBOT
Soybean, Corn and Wheat Options. It is designed to ensure that the number of listed strikes is
responsive to the needs of market participants without being excessive.

The CBOT intends to implement these amendments no sooner than one day after the
Commission’s receipt of this submission. Implementation of these amendments will not cause
the delisting of any Soybean Oil Options strikes which have open interest.


May 18, 2007
Ms. Eileen A. Donovan
Page Two

There were no opposing views conceming these amendments.

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

Sincerely,

Paul J. Draths
Vice President and Secretary

b051507


Additions are bolded and underlined and deletions are bracketed and struck through

3204.01 Striking Prices - Trading shall be conducted for put and call options with striking
prices (the "strikes") in integral multiples of one-half cent per pound per Soybean Oil futures
contract (i.e., .210, .215, .220, etc.) (the "first tier"); and in integral multiples of one cent per
pound per Soybean Oil futures contract (i.e., .210, .220, .230, etc.) (the "second tier") as follows:

1. a. Per the first tier, at the commencement of trading for an option contract, the
following strikes shall be listed: one with a strike closest to the previous day's
settlement price of the underlying Soybean Oil futures contract, the next five

consecutive higher and the next five consecutive lower strikes [and-a

rb d-belew-that- strike} (the "initial band").
If the previous day's settlement price is midway between two strikes, the closest
price shall be the larger of the two.

b. Per the second tier, at the commencement of trading for an option contract, the
following strikes shall be listed: the next four consecutive strikes above the initial
band.

c. Per the first tier, over time, strikes shall be added as necessary to insure that all
strikes within [5]2.5 cents of the previous day's trading range of the underlying
futures contract are listed (the "minimum band").

d. Per the second tier, over time, strikes shall be added as necessary to insure that the
next four consecutive strikes above the minimum band are listed.

e. No new strikes may be added by these procedures in the month in which an option
expires.

2. All strikes will be listed prior to the opening of trading on the following business day.
The Exchange may modify the procedures for the introduction of strikes as it deems
appropriate in order to respond to market conditions.