Appendix 8

Survey of Responses from IOSCO SRO Consultative Committee members1

Table 1 Whether broad based or narrow based indexes are traded and what other related products are traded

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) According to the ASE, stock index derivatives products in Greece are only based on broad based indexes. In particular, the FTSE/ASE 20, FTSE/ASE Mid 40 and FTSE/ASE SmallCap Indices have been designed to provide real time measures of the Athens Stock Market on which index-linked derivatives can be traded. The FTSE/ASE 20 Index is the large cap index, capturing the 20 largest blue chip companies within the Athens market as agreed by the FTSE/ASE Indices Advisory Committee. The FTSE/ASE Mid 40 Index is the mid cap index and captures the performance of the next 40 companies as agreed by the FTSE/ASE Indices Advisory Committee. The FTSE/ASE SmallCap Index is the small cap index and captures the performance of the next 80 companies as agreed by the FTSE/ASE Indices Advisory Committee. Currently, index futures and index options on the FTSE/ASE 20 and FTSE/ASE Mid 40 are traded in Greece. Further, covered warrants are not listed and traded in the market but are expected to start trading in 2003 as listed products, and no foreign securities are included in these indexes. Australian Stock Exchange (ASX) Index futures and index options on the ASE are based on both broad-based and industry sector indices. Options are also traded and a property sector index is traded as a narrow-based industry index based on listed property trusts. Index warrants are traded and are based on the Australian benchmark index (S&P/ASX200) and also based on overseas indices (S&P 500 and Nikkei). In Australia, futures and options are based on domestic securities index benchmarks and warrants are available for trading over domestic and foreign securities indices. The S&P/ASX200 and S&P/ASX50 indices do include foreign securities subject to the rules governing construction and maintenance of an index. However in Australia, there are no indices specifically comprised of foreign securities only. Chicago Board Options Exchange Stock index derivative products based on both broad based indexes and narrow based indexes are traded at CBOE. Additionally, CBOE lists a series of structured products that are linked to various indices. Indexes based on entirely foreign securities and combination of foreign and domestic securities are traded on CBOE. Some of the indices are constructed and maintained by CBOE while others are constructed and maintained by third parties. Various methodologies are used for calculating index levels. Index levels are calculated and disseminated every 15 seconds during the trading day by the parties which maintain that index. Euronext N.V The Euronext market trades in stock index derivative products based on broad- based indexes and covered warrants based on both broad based and narrow based indexes. Currently, the indexes comprise of domestic securities only, foreign securities could be included if they fulfill the necessary criteria. Japan Securities Dealers Association JSDA has three types of stock indexes related to the JASDAQ market and these are JASDAQ Index, NIKKEI TENTOU Average Index and the JASDAQ-BLOOMBERG Index. With regard to the first two indexes, index

1 Organization without indexation relative to derivative products: Istanbul Stock exchange: As Turkey’s only securities exchange, ISE trades currency futures and is not involved with derivative products on equities; NASD: NASD’s focus is on the OTC (Over-the-Counter) derivative market and not on exchange-traded derivatives. rebalancing does not occur, since both indexes are calculated with all JASDAQ registered issues in the JASDAQ market unless an index component stock is newly listed or de-listed. The JASDAQ-BLOOMBERG index has not seen any effects such as increased volatility or volume in response to index rebalancing. London Stock Exchange There are a number of UK index derivative products, such as the FTSE 100 Futures and Options Contracts, which are based on UK equity indices. These standardized contracts are generally traded on LIFFE. The underlying components are traded on one of the Exchange’s markets. Other derivative products are traded such as individual equity options and universal stock futures (traded on LIFFE) and warrants (traded on the Exchange). National Futures Association Stock index derivative products based on broad-based market indexes are currently traded at NFA. These include products comprised of foreign securities. By 4th quarter 2002, narrow based indexes will also begin trading. Covered warrants are not traded at NFA. Each individual market place can construct and maintain their own indexes. Moreover, several exchanges may list a similar index. Osaka Securities Exchange Co. OSE lists futures, options and EFTS such as Nikkei 225, Nikkei Stock Index 300, FTSE Japan, MSCI Japan and DJIA. Sao Paulo Stock Exchange Stock index derivative products based on broad based indexes are traded on BOVESPA and they consist of domestic securities only. Sydney Futures Exchange A broad based stock index derivative product, known as the SPI 200 is traded on the SFE. The S&P/ASX 200 index contains foreign (New Zealand) stocks. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 2 Which entities construct and maintain the underlying indexes

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) The management of both the underlying and broad based indices are carried out by three groups, the FTSE/ASE Indices Advisory Committee; FTSE International Limited and Athens Exchange S.A. Australian Stock Exchange (ASX) In Australia, the Standard & Poors constructs and maintains the underlying indices traded on the ASX Futures and Options market. The Standard & Poors (S&P) Australian Index Committee is responsible for setting policy, determining index composition and administering the indices. Chicago Board Options Exchange Some of the indices are constructed and maintained by CBOE while others are constructed and maintained by third parties. Euronext N.V The Euronext Brussels Exchange constructs and maintains the underlying indexes – BEL20 Index. Japan Securities Dealers Association The JASDAQ-BLOOMBERG index is the one index that is maintained and calculated jointly with Bloomberg P.L, which also serves as the calculation agent. The index that is maintained and calculated independently by a third party is the NIKKEI-TENTOU index. Although it is not used as an underlying asset for any derivative products, it may be used as a benchmark of performance for some mutual funds. London Stock Exchange In the UK, FTSE International is responsible for the creation and calculation of most of the major UK equity and derivative indices, such as the FTSE 100, the FTSE All-Share, and the FTSE 100 Futures. FTSE International is an independent company co-owned by the London Stock Exchange and the Financial Times. Morgan Stanley Capital International Inc, (“MSCI”) is also an index provider and distributes data in respect of its various indices. National Futures Association Each individual market place can construct and maintain their own indices. Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange BOVESPA constructs and maintains the stock indexes. Sydney Futures Exchange All index construction, calculation and maintenance is performed by Standard and Poors. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange TSE calculates Tokyo Stock Price Index (TOPIX), a composite index of all the common stocks listed on the First Section of TSE, which is the benchmark for Japanese stocks, and operates Japanese equities and futures & options markets. NIKKEI 225, which is calculated by Nihon Keizai Shimbun S&P/TOPIX 150 was created through a joint collaboration between TSE and Standard & Poor’s, and the derivatives based on it are listed on TSE. TSE and Standard & Poor’s have set up an Index Committee where both parties discuss the index component stocks and other related matters.

Table 3 Methodology used to calculate index levels

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) Last trade prices for securities as disseminated by the Athens Exchange S.A are used to calculate index levels every 30 seconds. Australian Stock Exchange (ASX) The indices are market-capitalization weighted indices and currently use the Global Industry Classification Standards (GICS) approach. From October 1, 2002, calculation of the index levels will move to a Free Float methodology. Chicago Board Options Exchange Various methodologies are used for calculating index levels. Euronext N.V As for the methodology used to calculate index levels, the BEL20 Index is used as a basket index based upon the Free Float adjusted market cap of the 20 biggest and most liquid companies. The index weighting methodology used for the underlying indexes is market capitalization adjusted for Free Float. The Euronext Brussels Index Compiler calculates the index levels. Index levels are calculated and disseminated on a tick change basis. The NSC trading platform is the source used for the prices of the component securities when calculating the index levels. Japan Securities Dealers Association --- London Stock Exchange The equity index values are based upon Exchange prices, which are received by FTSE International on a real-time basis. The process for calculating the composition of UK indices is very transparent and the market is fully aware of those securities that are to be moved following a re-weighting. In summary, FTSE International undertakes a quarterly re-weighting which determines the composition of the various indices for the next quarterly period. The re-weighting takes place on the third Friday of every quarter in March, June, September and December. MSCI also has a transparent process for calculating the composition of its indices. National Futures Association --- Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange The index levels are calculated using the portfolio of the most liquid stocks where each component has an established quantity according to its market liquidity. The index level is calculated every 30 seconds. Sydney Futures Exchange The SFE uses a combination of market capitalization and free float to calculate index levels and this is calculated by Standard and Poors every 30 seconds. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 4 Where traded and regulated

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) Both cash and derivatives are traded on the Athens Exchange S.A (formed by the merger of the Athens Stock Exchange S.A and Athens Derivatives Exchange S.A). The Hellenic Capital Market Commission (HCMC) is the government regulator of stock index derivatives products and is the entity that sets market/SRO rules together with the Board of Directors of the Athens Exchange and of the Athens Derivatives Exchange Clearing House (ADECH). Australian Stock Exchange (ASX) In Australia, derivative products trade on the ASX and also another Exchange. Futures do not trade on the same Exchange. Financial markets in Australia are regulated by the Australian Securities & Investments Commission (ASIC). Derivative products traded on ASX (options and warrants) and ASXF (futures) are subject to market rules called “Business Rules. The market rules are enforced by the Exchanges and all stock index derivative products are subject to market/SRO rules. Chicago Board Options Exchange Both the derivative product and the underlying security may trade on the same exchange. Euronext N.V Both the derivative products and the underlying securities trade on the same exchange but on different platforms. Approval from the Market Authority and the CBF is necessary prior to listing stock index derivative products on Euronext. Japan Securities Dealers Association --- London Stock Exchange See table 1. National Futures Association Security products such as stocks and stock indices trade on securities exchanges while the derivative products (futures and options) trade on derivative exchanges. The broad based index futures products are regulated by the Commodity Futures Trading Commission (CFTC). The narrow based index futures products and single stock futures are regulated by both the CFTC and the U.S. Securities Exchange Commission (SEC). Stock index derivative products are subject to the rules of the market on which they trade and also the SRO designated for the market. The CFTC has to grant approval prior to listing of a stock index derivative product. Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange Both the derivative products and the underlying securities are traded on BOVESPA. The Brazilian SEC (CVM) regulates BOVESPA and authorizes new listings. Sydney Futures Exchange According to the SFE, derivative products do not trade on the same exchange as the underlying securities. The Australian Securities and Investments Commission (ASIC) regulates both the derivatives and securities market in Australia. Operators of Exchanges are the front line regulators for these markets and are subject to ASIC oversight. Stock index derivative products are subject to market/SRO rules. The rules are contained in the operating rules of the SRO. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 5 Regulation establishing design or listing standards for stock index derivative products

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) The Greek Law 2533/1997 sets the relevant legal and statutory framework of the operation of the Greek derivatives market. There are certain limitations on the types of securities that may be included in an index. For example, shares must be listed on the Athens Exchange to be eligible for inclusion and a company must be incorporated and resident for tax purposes in Greece to be eligible Australian Stock Exchange (ASX) The Business Rules govern the listing standards for both warrants and options. The laws regulating warrants go to the legal characterization of a warrant rather than the design or listing standards and the listing standards for options are also non-specific. Listing standards for stock index futures are governed by a Business Rule of the ASX Futures Exchange and listing standards for stock index options are governed by a Business Rule of the ASX

Chicago Board Options Exchange CBOE is regulated by the U.S. Securities and Exchange Commission. The rules which govern activity are CBOE rules. The listing standards for stock index derivative products must comply with Section 19(b) of the Exchange Act. Euronext N.V Approval from the Market Authority and the CBF is necessary prior to listing stock index derivative products on Euronext. Japan Securities Dealers Association --- London Stock Exchange --- National Futures Association In order to list security futures products for trading the designated contract market or registered derivatives transaction execution facility must provide the CFTC with a certification that the specific security product(s) meet the criteria outlined in the Commodity Exchange Act Part 41, Subpart C-Requirements and Standards for Listing Security Futures Products. The Commodity Exchange Act Part 41, Subpart C-Requirements and Standards for Listing Security Futures Products describes in detail the listing standards and regulations for security futures products. Furthermore, each market may have their own guidelines or rules which must adhere to the CFTC’s listing requirements but may be more stringent. Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange --- Sydney Futures Exchange According to the SFE, there are no regulations establishing the design or listing standards for stock index derivative products other than the robustness of the exchange in maintaining a fair and orderly market. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 6 Clearance and settlement requirements

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) The calculation of the daily settlement price is performed during the last ten minutes before closing of the Athens Stock Exchange and for contracts traded during this period, the settlement price is the weighted average of the prices of trades occurring during this period. If no trades occurred during this period, settlement price is calculated by applying on the settlement price of the previous trading day, the percentage change of the settlement price of the “liquid month”. Final settlement price is calculated using the closing price of the underlying index at the expiration day as calculated by the ASE. At the ASE, all stock index derivative products are cash settled as opposed to physical delivery. Australian Stock Exchange (ASX) ASX has a derivatives pricing system – DPS. The approach is that throughout the trading day, DPS calculates and builds an implied volatility database for every listed series/strike based on every bid/ask/ trade passed from the trading system. The settlement prices for the underlying securities/indices taken at market close, currently 4:05 p.m. are then applied to the implied trade volumes to determine derivatives settlement prices. Interpolation and extrapolation are applied for inactive series and the Risk Management unit makes some manual adjustments as it sees appropriate. No stock index derivative products are settled by physical delivery. Chicago Board Options Exchange --- Euronext N.V --- Japan Securities Dealers Association --- London Stock Exchange --- National Futures Association --- Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange --- Sydney Futures Exchange Attached as part of Exhibit J are the operating rules and contract specifications of the PI-200 futures contract traded on the SFE. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 7 Surveillance

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) With regard to facilitation of surveillance, the Athens Derivatives Exchange (ADEX) performs daily audit trails both historically and real time. Significant finding are reported to the Capital Market Committee (CMC) for further investigation. Coordinated surveillance takes place through the CMC that receives daily information from the ADEX and the ASE.

Australian Stock Exchange (ASX) See Table 8. Chicago Board Options Exchange --- Euronext N.V --- Japan Securities Dealers Association --- London Stock Exchange Under the Financial Services and Markets Act 2000, the FSA has overall responsibility for protecting the integrity of the UK’s financial market and its Code of Market Conduct gives overall guidance on whether behavior amounts to market abuse. The Exchange continues to be responsible for the real-time surveillance of trading on its markets in order to ensure that trading is orderly and efficient. During an index expiry period, when the futures and options settlement price is being calculated, the Exchange’s price monitoring system is disabled, in order to ensure continuous trading without interruption. During this period, the Exchange closely monitors the activity of market participants and investigates and notifies LIFFE and the FSA of any unusual trading activity. National Futures Association In order to provide surveillance services for securities futures product (“SFP”) trading and related inter-market activities, each exchange provides its SRO with access to the underlying security and/or option on security markets. This may be accomplished through access via the Consolidated Equity Audit Trail, a database of trade information provided through affiliation with the Intermarket Surveillance Group (“ISG”). Furthermore, each derivatives market allows its SRO the right to request, through the market’s member firms more detailed trade information when necessary. Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange The surveillance procedures used to supervise equity transactions are applied to the derivative products. Sydney Futures Exchange Trading workstation and interface activity logs and mandatory voice logs of all order placement must be maintained by Participants for specified periods to assist in Exchange query resolution and surveillance investigations. Coordinated surveillance takes place through close liaison between the Trading Operations function and Surveillance functions of SFE to allow both real time and post-trade surveillance monitoring. A Memorandum of Understanding (MOU) is in place between SFE and ASX (the market on which the equity index is traded) to facilitate cooperation and confidential information sharing market surveillance and related investigation matters. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 8 Regulators

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) There are requirements that ADEX has to meet on a daily basis to provide information to regulators (HCMC) for all derivative products traded in ADEX. These comprise of Daily Transaction and Position Reports and certain special reports. Australian Stock Exchange (ASX) There are processes in place at the ASX and the ASXF for providing information to regulators (ASIC) through respective information sharing arrangements. Chicago Board Options Exchange See Table 5. Euronext N.V See Table 5. Japan Securities Dealers Association --- London Stock Exchange See Table 7. National Futures Association See Table 7. Osaka Securities Exchange Co. --- Sao Paulo Stock Exchange --- Sydney Futures Exchange No requirement exists for SFE to provide regulators with information unless it is included in a formal referral to ASIC as a result of a surveillance investigation. SFE is the front-line regulator of its market, with the power to investigate and take disciplinary action against its Participants only. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange ---

Table 9 Manipulation and front-running

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) In Greece, both in the cash market and in the derivatives market, trading and clearing occurs at an end client level. Consequently, the supervision of the cash and derivatives market can run parallel tests to detect cases of possible front running. As far as index design, tests are conducted for trades conducted in the cash market and trades or positions in the derivatives market for affiliated groups or persons, to prevent and detect possible manipulation of an index. Australian Stock Exchange (ASX) Derivatives and securities are all financial products, and as such are subject to market misconduct provisions. In addition, market operators do impose an equivalent prohibition on market manipulation and insider trading through their rules. Front running is not permitted and there are rules that deal with client order precedence. Arbitrage between stock values is permitted. Chicago Board Options Exchange --- Euronext N.V --- Japan Securities Dealers Association --- London Stock Exchange See Table 7. National Futures Association --- Osaka Securities Exchange Co. OSE exchanges information on an as needed basis with each index provider. There has been no known case of manipulation of the price of the index component stock in order to profit from relative cash derivatives positions. Sao Paulo Stock Exchange --- Sydney Futures Exchange The Corporations Act 2001, contain general anti-manipulation, insider trading and takeover provisions, which may apply to trading in index derivatives. The SFE’s Business Rules also contain anti-manipulation provisions, which apply to derivatives trading. Inter-market front running is addressed through SFE’s Business Rules. Taiwan Stock Exchange Corp. --- Tokyo Stock Exchange The Surveillance Department of TSE is monitoring carefully whether the final settlement prices of index derivative products are manipulated or not. There has never been any serious problem caused by price manipulation because the number of component stocks of TOPIX is very large and the impact of each stock price movement on TOPIX is so limited as mentioned in Answer 1. The Surveillance Department of TSE also watches carefully the transactions on SQ(Special Quotation) day in order to find out stock price manipulation. There have been a couple of suspicious cases, which had proved not to be illegal after the investigation.

Table 10 Index rebalancing

IOSCO SRO Consultative Response Committee Member Athens Exchange S.A (ASE) The Advisory Committee meets semi-annually to review constituents of the indices. Certain rules address the methodology to be used for index rebalancing. Other factors leading to rebalancing include new issues and suspension of dealing. The ASE has not detected a significant price effect from the rebalancing of the FTSE indexes and the equity derivatives based on them and this is because changes are announced early and the market absorbs them over a period of a month from the semi-annual implementation of the changes. Australian Stock Exchange (ASX) In Australia, the entity that establishes criteria for rebalancing indices is the S&P, which usually reviews the indices on a quarterly or as needed basis when significant corporate events occur. As a result of index rebalancing, market participants have observed short term pricing impacts, but this is at the level of the underlying securities. The opening level of index levels is reset by the index provider to the same level before the index rebalancing. Generally speaking, the ASE has observed only minor and short-lived impacts due to an awareness of pending changes allowing for adjustment and the stringent liquidity requirements for index constituents that minimizes the impact of increased demand for the security. Chicago Board Options Exchange The original designer of the index establishes the criteria for rebalancing. CBOE has noticed no price impact resulting from index rebalancing. Euronext N.V Index rebalancing criteria is established by BEL20 Index Supervisor with assistance from the BEL20 Index Advisory Committee. There are ground rules for index annual rebalancing and replacement of constituents. Rebalancing usually takes place on the 1st trading day in March based on end of December figures. Index announcements are made public after market close. No short-term price impacts are expected as a result of index rebalancing. With regard to the price of derivatives products being affected by the price of the component stocks, heavy trading volumes and price manipulation have been experienced. Japan Securities Dealers Association See Table 1. London Stock Exchange See Table 2. Heavy volumes may be experienced during the rebalancing event causing some price volatility and the Exchange will closely monitor trading during this period. National Futures Association --- Osaka Securities Exchange Co. In April 2000, 30 constituents of Nikkei 225 were replaced. In this case, index rebalancing was blamed for the large decline in the index value even though no securities firms were charged. OSE does not conduct any special surveillance for index rebalancing. OSE participates in information exchange with Tokyo Stock Exchange as a measure to prevent illicit transactions between the cash market and the derivatives market. Sao Paulo Stock Exchange Rebalancing is done every four months and the information is disseminated prior to the opening of the trading session. Sydney Futures Exchange The entity that establishes criteria for rebalancing indexes is Standard & Poor’s. The index provider and the operator of the underlying market upon which the actual index is listed generally handle the advance notification of index changes, the timing of index rebalancing and any confidentiality issues with respect to changes in the design or components of an index. The price impact resulting from index rebalancing is considered insignificant. Taiwan Stock Exchange Corp. TSE does not have specific surveillance measures for situations where index rebalancing could potentially impact component stock prices. Further, the Taiwan Futures Exchange (TFE) on which the TAIEX futures, the TSEC Electronic Sector Index futures, and the TSEC Banking and Insurance Sector Index futures trade, have not seen price manipulation occur in order to affect indexes for gains from the related cash derivatives position.

Tokyo Stock Exchange The Department of Index Calculation is responsible for rebalancing of the TOPIX in cooperation with the Cash & Derivative Market Departments. The TKSE has not experienced serious problems caused by rebalancing of the TOPIX due to the large number of component stocks that list on the TOPIX, which creates minimal impact by the underlying stock movement. When the component stocks of NIKKEI 225 were reviewed, 30 stocks were replaced. Due to the large number of stocks replaced, volatility and trading volume in the stocks to be replaced did increase and the prices of newly added stocks jumped whereas prices in stocks to be replaced were sharply down. TKSE, as an operator of a derivative market coordinates closely with other markets such as the Osaka Securities Exchange and Standard & Poor’s.