Division of Clearing and

Risk

Division of Swap Dealer

and Intermediary

Oversight

U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

115521 st Street, NW, Washington, DC 20581

Telephone: (202) 418-5000

Facsimile: (202) 418-5547

aradhakrishnan@cftc.gov

gbarnett@cftc.gov

Ananda Radhakrishnan

Director, DCR

Gary Barnett

Director, DSIO

November 7,2011

Mark G. Bagan, President and CEO

Minneapolis Grain Exchange

111 Grain Exchange Building

400 South 4th Street

Minneapolis, Minnesota 55415

Re: Notification of Post-Relief Transfer Pursuant to Commission Regulations 190.02(a)(2) and

190.06(g)(2)(i)

Dear Mr. Bagan:

This letter is in response to your letter, written on behalf of the Minneapolis Grain

Exchange (MGEX), dated November 4, 2011 (the MGEX Letter), notifying the Commission of

MGEX's transfer of certain customer positions as a result of the insolvency proceedings of MF

Global, Inc. (MF Global), one of its clearing members. The MGEX Letter is pursuant to

Commission Regulation 190.02(a)(2), which requires a clearing house, prior to transferring

customer positions under Section 764(b) of the Bankruptcy Code, to notify the Commission of

its intent. If the Commission is so notified and does not disapprove pursuant to Commission

Regulation 190.06(g)(2)(i)(B), such transfer may not be avoided by the bankruptcy trustee.

In order to minimize disruption to the markets and to protect the integrity of the

marketplace and market participants, MGEX proposed transferring certain MF Global customer

segregated account positions. The transferees will be one or more eligible clearing members of

MGEX identified in the MGEX Letter and willing to accept such positions. Specifically, MGEX

requests to transfer positions to one or more ofthe following eligible clearing members: [ ],

[ ],[ ],[ ],

[ ] and other transferees that are eligible clearing members ofMGEX. MGEX

expects that a significant portion of the margin would be transferred to [ ],

an FCM omnibus account at [ ].
Page 2

The Division of Clearing and Risk (DCR) and the Division of Swap Dealer and

Intermediary Oversight (together with DCR, the Divisions) have reviewed the MGEX Letter.

Under Commission Regulation 190.06(g)(2)(i)(B), if the Commission does not disapprove the

transfer, such transfer may not be avoided by the bankruptcy trustee. Acting pursuant to the

authority delegated to it by Commission Regulation 190.1 O(d), the Divisions hereby notify you

that the Commission does not disapprove the transfer of the positions set forth in the MGEX

Letter in the manner described therein. In addition, in the event that one or more of the transfers

are not permissible under Commission Regulation 190.06(g)(2)(i)(B) on the grounds that they

are deficit accounts, the Commission authorizes such transfers under Commission Regulation

190.06(h)(2).

The Commission reiterates that customer segregation is the foundation of customer

protection in the commodity futures and swaps markets. Segregation must be maintained at all

times, pursuant to Section 4d of the Commodity Exchange Act (the Act) and Commission

Regulation 1.20. As mentioned above, MF Global does not have sufficient funds in segregation

to meet Commission requirements. The Commission intends to take any and all action afforded

to it, within the purview ofthe Bankruptcy Code and the Act, to ensure that customers maximize

their recovery offunds and to discover the reason for the shortfall in segregation.

This letter is based upon the representations of MGEX and applicable laws and

regulations in their current form. If you have any questions concerning this correspondence,

please contact Jon DeBord, Special Counsel, DCR, at 202-418-5478 or jdebord@cftc.gov.

Sincerely,

Gary Barnett

Director, DSIO

2

Anan a Radhakrishnan

Director, DCR