FINANCIAL AND REGULATORY BULLETIN

#15-01

TO:            Chief Financial Officers
                  Chief Compliance Officers
                  Credit/Risk Manager
                  SPAN/Margin Contact

DATE:         January 2, 2015

SUBJECT:     CBOT Rule 930.C. Acceptable Performance Bond Deposits

In an effort to further harmonize performance bond and collateral acceptance practices across CME, CBOT, NYMEX and COMEX, the following CBOT Notices1 will be rescinded effective June 30, 2015:

        1. CBOT Notice dated May 19, 2005: Clarification to Regulations 431.01 & 431.06 Margins – Non-Clearing Members. Broadly stated, the Notice allowed a defined portion of an individual CBOT member’s seat value to be considered as performance bond collateral within a limited set of circumstances.

        2. CBOT Notice dated November 4, 2005: Non-Clearing Members – Margin. This Notice addressed the use of CBOT Common Stock as performance bond collateral and clarified certain aspects of the Notice dated May 19, 2005.

Individual CBOT Members will continue to receive the benefits of reduced transaction fees and member performance bond requirements at the maintenance rather than initial performance bond level within the division of membership held. Please refer to CBOT Rule 930.C.for the types of performance bond that may be accepted by clearing members from their account holders.

If you have any questions, please contact the Financial and Regulatory Surveillance Department at 312-930-3230.