The reportable level for the new TRAKRS product is 25,000 contracts. Any position that meets or exceeds this level must be included in a firm's daily submission of Large Trader Reportable (LTR) data.

When reporting positions that meet or exceed the reportable level in the daily LTR submission for TRAKRS to the CME and CFTC, the last 3 digits of this position must be truncated to accommodate space limit in the current format. We are looking for a simple truncation rather than attempting any rounding of positions. Therefore, a position of 25,999 long in December 2002 for example, would be reported as simply 25. Positions of less than 1000 contracts would not be reported in the LTR submission.

Should you have any questions regarding this matter, please contract Ray Menghi at (312) 648 3661.