cme é

Chit Mercantile Exchange
705 JEE1E AL & GO nage Meare
20 South Wacker Drive
OFC. OF THE SECRETARIAT Chicago, IL 60606-7499

www.cme.com

June 13, 2005

Ms. Jean A. Webb

Office of the Secretariat

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21" Street, NW

Washington, DC 20581

RE: CME Regulatory Advisory, RA-05-05
Submission No. 05-65

Dear Ms. Webb:

Chicago Mercantile Exchange Inc. (“CME” or “Exchange") hereby notifies the Commission that
the Exchange has issued a regulatory advisory to CME members, Clearing Member Firms, employees
and CME Globex® users regarding CME Rule 576 ("Identification of GLOBEX Terminal Operators.")
This rule specifies identification and registration requirements for individual workstation operators and
automated trading systems. A copy of this regulatory advisory is attached.

The Exchange certifies that this regulatory advisory neither violates nor is inconsistent with any
provision of the Commodity Exchange Act or of the rules and regulations thereunder.
If you have any questions regarding this matter, please call me at (312) 648-5422.

Sincerely,

/S/ Stephen M. Szarmack
Director and Associate General Counsel

‘SMS/elm/4341 SUB 05-65.doc


cme ¢@

Chicago Mercantile Exchange
20 South Wacker Drive 312/930.1000 tel
Chicago, It 60606-7499 312/466.4410 fax

www.cme.com

Regulatory Advisory
TO: All Members, Clearing Member Firms, Employees and RA-05-05
CME® Globex® Users (supersedes
RA-03-03)
FROM: CME Market Regulation Department
DATE: June 13, 2005

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

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.

While every person or Automated Trading System (“ATS”) entering orders through CME iLink
connections must be identified by a workstation operator identifier, registration of those IDs in
EFS is only required for members and their employees, employees of clearing members, and
other traders or employees of trading entities which are receiving preferential rates as a result of
membership, including Rule 106.R. (“Electronic Corporate Member Transfers” or ECMs), or
Participation in one of the special incentive programs including the New Trader Program, the
Asian Incentive Program (“AIP”) and the European Incentive Program (“EIP”). 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.

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

(over)


CME Regulatory Advisory 05-05
June 13, 2005
Page 2

Individual Workstation Operators

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 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

All operators of ATSs must file with CME an Automated Trading System Connection
Registration form (Schedule 8), which can be downloaded at
http:/Awww.cme.com/files/CMEGlobexSch8ATS.pdf. This formshould be submitted to the
Globex Account Management Department via fax at 312/634.1568. For questions on Schedule
8, please contact Globex Account Management at 312/634.8700 or via email at
globexaccountmanagement@cme.com.

Additionally, for all ATSs that do not require an individual to initiate or manually confirm the
creation of a specific instruction, a workstation operator identifier must still be provided in FIX
Tag 50. A different Tag 50 value should be used for each independent model, algorithm,
program, and/or process under each ATS owner. 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.

Within its records the clearing firm should associate this ATS workstation code with the person
who is directly responsible for administrating the trading of that ATS system, and should follow
all procedures and requirements to appropriately register the workstation operator identifier in
EFS.

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