For your convenience, attached is CME Group Fee Policy Bulletin # 08-01 dated December 9, 2008.

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FEE POLICY BULLETIN

TO: Chief Financial Officers
Chief Compliance Officers
Corporate Members
New Firm Approval Contacts
Firm EFS Contacts

FROM: Audit Department, Clearing House Division

DATE: December 9, 2008

SUBJECT: Clearing and Globex® Fees for Member Firm Accounts

CME Group Inc. (“CME Group”) sets the fee policies for its four subsidiary exchanges - Chicago Mercantile Exchange Inc. (“CME”), Chicago Board of Trade, Inc. (“CBOT”), New York Mercantile Exchange, Inc. (“NYMEX”) and Commodity Exchange, Inc. (“COMEX”). In response to market participant feedback, CME Group is enhancing and clarifying documentation of, and where possible harmonizing, its fee policies for CME, CBOT, NYMEX and COMEX.

In February 2007, CME issued Fee Policy Bulletin (”FPB”) #07-01 concerning Clearing and Globex Fees. CME Group is issuing this FPB to enunciate CME, CBOT, NYMEX, and COMEX member fee eligibility policies and to update and clarify them as needed. This FPB supersedes all previous bulletins discussing fee policy issues for member firm accounts.

CME Group has met with several CME, CBOT, NYMEX, and COMEX trading firms to better understand their operations and the impact of our fee policies. From these meetings, the overwhelming consensus was the desire for clear, defined, and harmonized fee policies between the four exchanges. This FPB seeks to achieve these goals.

The trading activity of member firms must adhere to our policies in order to be granted member fees – equity member or preferential fees as applicable. CME Group has established member firm trading policies to ensure that the trading activity conducted for the member firm account is for the sole benefit of the member firm itself and not the trading activity of individual customers/traders conducted in the name of the firm; i.e. to prevent arcade type trading under the guise of member firm trading and the “selling” of member firm rates. To that end, the financial benefit and risk of the trading activity must be solely of the member firm. Further the member firm may only profit/benefit from the member firm trading activity through the performance of the trade and not from any other source such as a commission or charge for trade execution.

The trading environment and the customer base has evolved and expanded over the years. We have seen a tremendous growth in both clearing and corporate membership for trading groups. These trading groups have their own unique capitalization, ownership structures, trader compensation and trading styles.

This FPB presents both Requirements (Absolutes) and Best Practices for defining when member firm trading activity will be granted member fees. In recognition of the varying trading operations, Best Practices were established to allow member firms to utilize certain business practices (most not allowed in the past) which are generally prohibited. In order to do so, the member firm must clearly demonstrate to CME Group their application of these non-compliant practices is not inconsistent with CME Group’s goal of providing member fees for trading activity for the account and sole benefit of the member firm.

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Should you have any questions or require any further information, please contact ExchangeInformation@cmegroup.com