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

Jeff C. Borchardt, President and CEO

Kansas City Board ofTrade

4800 Main Street, Suite 3000

Kansas City, Missouri 64112

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

190.06(g)(2)(i)

Dear Mr. Borchardt:

This letter is in response to your letter, written on behalf of the Kansas City Board of

Trade (KCBOT), dated November 4,2011 (the KCBOT Letter), notifying the Commission ofthe

KCBOT'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 KCBOT 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, the KCBOT proposed transferring certain MF Global

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

members of KCBOT identified in the KCBOT Letter and willing to accept such positions.

Specifically, the KCBOT requests to transfer positions to one or more of the following eligible

clearing members: [ ], [ ], [ ],

[ ], and [ ].

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

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

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

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 KCBOT

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 of the Bankruptcy Code and the Act, to ensure that customers maximize

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

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

regulations in their CUlTent 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,

~.~~.~a~~~.adhakrishnan

ctor, DCR

Gary Barnett

Director, DSIO

2