Audit Advisory Notice

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From Audit Department, Clearing House Division
Subject Intepretation to Chapter 9 � The Capital Charge for a Rule 106.D.
Effective Date 03/29/00
Notice Number 00-02

Intepretation to Chapter 9 � The Capital Charge for a Rule 106.D. Transferee (Lessee) and Trading Permit Holder

The CFTC recently approved the elimination of the Interpretation to Chapter 9 � Capital Charge for a Rule 106.D. Transferee (Lessee) and Trading Permit Holder.

With the changing environment and today�s sophisticated risk management systems, the internal lessee capital charge, originally adopted in 1982, no longer serves its purpose. The dollar amount of the charge ($50,000 for lessees and $25,000 for trading permit holders) is not considered sufficient to cover serious trading losses. Further, financial capitalization above Exchange-mandated performance bond requirements of accounts (including those of lessees) should be a business decision of clearing members.

Thus, effective with the March 31st, 2000 financial statement filing, you will no longer be required to submit the number of lessees subject to a charge and charge amount.

If you have any questions, please call the Audit Department at (312) 930-3230 or e-mail at audits@cme.com.