Attached please find a proposed new Copper Options Rule XX.XXX which would permit the trading of Average Price Options (“APO”) in the Grade 1 Copper Futures Contract.

The proposed new Copper Options Rule XX.XXX affects a “Special Matter” under the terms of the COMEX By-Laws. Accordingly, COMEX Division Members have ten (10) days to submit a petition signed by owners of at least 155 COMEX Division Memberships requesting a vote of the COMEX Division Members to disapprove the amendments, pursuant to the procedures set forth under COMEX By-Law 205(D). If a petition is not received, or if the amendment is not disapproved, it will be submitted to the Commodity Futures Trading Commission (CFTC).

Proposed new rule

COPPER AVERAGE PRICE OPTION CONTRACT

XX.01 EXPIRATION OF COPPER AVERAGE PRICE OPTION

A Copper Average Price Option on the Exchange shall expire at the close of trading on the last business day of the calendar month. The expiration date shall be announced prior to the listing of the option contract.

XX.02 TRADING UNIT COPPER AVERAGE PRICE OPTION CONTRACTS

A Copper average price call option traded on the Exchange represents the differential between the arithmetic average of the settlement price of the first nearby Copper Futures contract over all the business days of a calendar month of trading, rounded to the nearest hundredth of a cent, less the strike price, or zero whichever is greater. A Copper average price put option represents the differential between the strike price and the arithmetic average of the settlement price of the first nearby Copper Futures contract over all the business days of the last calendar month of trading, rounded to the nearest hundredth of a cent, or zero whichever is greater. If the arithmetic average is precisely between two price increments, it shall be rounded to the higher price increment.

XX.03 TRADING MONTHS IN COPPER AVERAGE PRICE OPTION CONTRACTS

Trading in Copper Average Price Option Contracts shall be conducted in the months as shall be determined by the Board of Governors (the “Board”). Trading shall commence on the day fixed by the resolution of the Board.

XX.04 HOURS OF TRADING IN COPPER AVERAGE PRICE OPTION CONTRACTS

The hours of trading in Copper Average Price Option contracts shall be the same as the hours of trading in Copper Futures contracts. All such trading shall take place on the trading floor of the Exchange within the hours prescribed by the Board.

XX.05 STRIKE PRICES FOR COPPER AVERAGE PRICE OPTION CONTRACTS

(A) Trading shall be conducted for options with strike prices in increments as set forth below.

(B) On the first business day of trading in an option contract month, trading shall be at the following strike prices: (i) the previous day's settlement price for Copper Futures contracts in the corresponding delivery month rounded off to the nearest two-cent increment strike price unless such settlement price is precisely midway between two two-cent increment strike prices in which case it shall be rounded off to the lower two-cent increment strike price and (ii) the six two-cent increment strike prices which are six increments higher than the strike price described in (i) of this Rule xx.05(B) and (iii) the six two-cent increment strike prices which are six increments lower than the strike price described in (i) of this Rule xx.05(B).

(C) Thereafter, on any business day prior to the expiration of the option (i) new consecutive two-cent increment striking prices for both puts and calls will be added such that at all times there will be at least six two-cent increment strike prices above and below the at-the-money strike price available for trading in all options contract months.

(D) Notwithstanding the provisions of subsections (A) through (C) of this Rule, if the Board determines that trading in Copper Average Price Options will be facilitated thereby, the Board may, by resolution, change the increments between strike prices, the number of strike prices which shall be traded on the first day in any new option contract month, the number of new strike prices which will be introduced on each business day or the period preceding the expiration of a Copper Average Price Futures Option in which no new strike prices may be introduced.

XX.06 PRICES IN COPPER AVERAGE PRICE OPTION CONTRACTS

Prices shall be quoted in dollars and cents per pound. The minimum price fluctuation shall be five (5) one hundredths of one cent per pound. A cabinet trade may occur at a price of $.004 per pound, or $1.00, however, if it results in the liquidation of positions for both parties to trade.

XX.07 ABSENCE OF PRICE FLUCTUATION LIMITATIONS FOR COPPER AVERAGE PRICE OPTION CONTRACTS

Trading in Copper Average Price Option contracts shall not be subject to price
fluctuation limitations.