G~ CMEGroup ACME/Chicago Board of Trade Company 

Via Electronic Delivery 

Mr. David A. Stawik 

Secretary of the Commission 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

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September 12, 2007 

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Received CFTC @ 

Records Section 

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COMMENT 

Craig S. Donohue 

Chref Executive Officer 

Re: Amendments Pertinent to Registered Entities and Exempt Commercial Markets -

72 Fed. Reg. 45185 (August 13, 2007) 

Dear Mr. Stawik: 

CME Group Inc. ("CME GroupTM") appreciates the opportunity to comment on several aspects of 

the Commodity Futures Trading Commission's ("Commission") proposed amendments pertinent to 

Registered Entities and Exempt Commercial Markets. 

CME Group is the world's largest and most diverse exchange. Formed by the 2007 merger of two 

designated contract markets ("DCMs"), Chicago Mercantile Exchange Inc. ("CME®") and the Board of 

Trade of the City of Chicago, Inc. ("CBOT®"), CME Group serves the risk management needs of 

customers around the globe. As an international marketplace, CME Group brings buyers and sellers 

together on the CME Globex® electronic trading platform and on its trading floors. CME Group offers the 

widest range of benchmark products available across all major asset classes, including futures and 

options based on interest rates, equity indexes, foreign exchange, agricultural commodities, energy, and 

alternative investment products such as weather and real estate. CME is also the largest derivatives 

clearing organization ("DCO") in the world. 

The Commission has proposed to amend Commission Regulation 40.1 (g) to modify the definition 

of "emergency" to explicitly recognize that persons other than members of the governing board of a 

registered entity may determine that a particular circumstance or event constitutes an emergency. The 

amendment would further specifically require that the rules of the registered entity must specify those 

persons authorized to determine that an emergency exists and the procedures for the exercise of 

emergency authority by those persons. CME Group supports the Commission's proposed amendments to 

Regulation 40.1 (g). The Commission has appropriately recognized that, given the time constraints that 

may be involved in convening the governing board, an authorized committee or an exchange official 

would likely be able to respond more quickly to the exigencies of an emergency situation. 

CME Group also agrees with the Commission's recommendations to permit registered DCMs that 

comply with the reporting requirements of Commission Regulation 16.01 (a) and (b) to implement certain 

rule changes without notification to the Commission. In particular, these rule changes include early 

listings of trading months within currently established cycles of trading months and changes to option 

contract rules relating to strike price listing procedures, strike price intervals, and the listing of strike prices 

on a discretionary basis. As noted by the Commission, the adoption of these amendments will avoid 

duplicative filing requirements for DCMs as well as permit the Commission to better utilize its resources. 
Mr. David A. Stawick 

Commodity Futures Trading Commission 

Page2 

We would be happy to discuss any of the issues raised by the Commission's proposed 

amendments with Commission staff. If you have any questions, please feel free to contact Anne Polaski, 

Associate Director, Regulatory Counsel, at (312) 435-3757 or apolaski@cmegroup.com. 

Sincerely, 

~j' S: iM ~ Craig S. Donohue 

Chief Executive Officer 

CME Group Inc. 

20 South Wacker Drive Chicago. Illinois 60606 T312 930 8275 F312 930 3209 craig.s.donohue@cmegroup.com cmegroup.com