Dor.~ovar~, Eileen A. 

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From: Gizzarelli, Jason 

Sent: Monday, May 07, 2007 2:54PM 

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COMMENT ; 

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Page 1 of2 

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To: Donovan, Eileen A. ~ . • _ ~ _ .-- . , - , · . -- 1'\ · -· · · \ - L. l.J .- t •• _-__ '"' ,-__ .. ,~ t.. • • \I. • 

Subject: FW: A note from Dennis Gartman; Outside Director of the Kansas City Board of Traae 

From: Dennis Gartman [mailto:dennis@thegartmanletter.com] 

sent: Friday, May 04, 2007 8:29AM 

To: Dunn, Michael 

Subject: A note from Dennis Gartman; Outside Director of the Kansas City Board of Trade 

Dear Mr. Dunn, 

Recelve<I_~FTC 

Records Section 

OT/ott /o1 

We met several weeks ago in San Francisco when I spoke to the National Grain Council 

meeting there, which you attended. I came up between meetings and introduced myself to 

you, taking that opportunity to explain why I thought the recent decision on public outside 

directors of the various exchanges was ill-advised. I am taking that opportunity again this 

morning in this e-mail to do the same. 

I serve on the KC Board of Trades' Board of Directors, for which I am paid $500/month, plus 

my traveling expenses to and from Kansas City. I have been involved in the markets since 

1974 when I began my career as the economist of Cotton, Inc., studying the cotton futures 

markets and hedging operations by the nation's mills, farmers, cotton gins, merchants etc. 

From there, I went to what was then NCNB (now the Bank of America) to trade foreign 

exchange and financial instrument futures. /left NCNB in 1979 to become the Financial 

Futures analyst for AG Becker in Chicago, and was an independent member of the CBOT 

until 1984, when I moved to Virginia, and guided the Virginia National Bank through the 

process of becoming the fist bank in the nation to have an internal futures commission 

merchant operation. In 1986 I began writing The Gartman Letter and have been doing that 

ever since ... along with teaching derivatives classes for the Federal Reserve Bank's School 

of Bank Examiners, speaking around the world to governments and central banks on the 

processes involved with futures and derivatives, and trading on a daily basis for my own 

account. I believe I have some modest level of expertise gained over these many years that 

serves the Kansas City Board of Trade well. 

The problem is that my clients for The Gartman Letter include a large majority of the top 100 

banks around the world, most of the top 100 hedge funds, many of the top 10 energy trading 

firms, several of the largest grain traders, mortgage bankers, etc. I clearly earn more than 

$100, 000/year from businesses directly related to the futures industry, and it is because of 

that relationship that your new rules will preclude me from remaining as a Director of the KC 

Board of Trade. This, I think, is a travesty, for my knowledge of the industry serves the 

Board and the public well. Living in Virginia, I commute to and from Kansas City once a 

month, remaining at a distance from the membership and thus serving as a perfect "outside 

director ..... " one with knowledge of the industry, but without the close proximity to the trading 

5/712007 
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floor that might colour my perspective on member floor problems, public vs. floor complaints, 

eta/. 

I consider it an honour and a privilege to be on the Board of Directors of the KG Board of 

Trade, and rest very mt:Jch assured /lose money each time I travel to and from Kansas City. I 

am clearly not in this business of being on the Board for the remuneration; I do it because I 

am honoured to serve the futures industry. 

Your recent decision to preclude me, and others in my position, from serving as an outside 

Director will serve the public ill, and I very respectfully ask that the Commission reconsider 

its decision in this matter. 

Warm regards, 

Dennis Gartman, Editor/Publisher 

The Gartman Letter 

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5/7/2007