Chicago Mercantile Exchange, Chicago Board of Trade, New York
Sean M. Downey Senior Director and Associate General Counsel Legal Department March 15, 2013 VIA E-MAIL Ms. Melissa Jurgens Office of the Secretariat Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington, DC 20581 RE: Regulation 40.6(a). Chicago Mercantile Exchange Inc./ The Board of Trade of the City of Chicago, Inc./ The New York Mercantile Exchange, Inc./ Commodity Exchange, Inc. Submission # 13-066: Revisions to CME, CBOT and NYMEX/COMEX Position Limit, Position Accountability and Reportable Level Tables Dear Ms. Jurgens: Chicago Mercantile Exchange Inc. (“CME”), The Board of Trade of the City of Chicago, Inc. (“CBOT”), The New York Mercantile Exchange, Inc. (“NYMEX”) and Commodity Exchange, Inc. (“COMEX”), (collectively, the “Exchanges”) are self-certifying revisions to the Position Limit, Position Accountability and Reportable Level Tables (collectively, the “Tables”) in the Interpretations & Special Notices Section of Chapter 5 in the Exchanges’ Rulebooks. The revisions will become effective on April 1, 2013 and are being adopted to ensure that the Tables are in compliance with CFTC Core Principle 7 (“Availability of General Information”), which requires that DCMs make available to the public accurate information concerning the contract market’s rules and regulations, contracts and operations. In connection with CFTC Core Principle 7, the Exchanges launched a Rulebook Harmonization Project with the goal of eliminating old, erroneous and obsolete language, ensuring the accuracy of all listed values (e.g., position limits, aggregation, diminishing balances, etc.) and harmonizing the language and structure of the Tables and product chapters to the best extent possible. The changes to the Tables are primarily stylistic in nature (e.g., format, extra columns, tabs, product groupings, etc.).
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