Five Year Futures Contract Overview First-in-first-out (FIFO) vs. Pro Rata Algorithm Pros and Cons of Each Methodology

Where Pro Rata Algorithm makes sense Low Volatility markets Constricted ranges Where market participation is inhibited

Where FIFO Makes Sense Markets with sufficient daily ranges Where volatility creates dynamic price action Where market users have opportunity to participate

Impact to GHCO FITE Traders Less ability to scratch FV trades Effect is magnified when the market slows Fewer FITE trading opportunities due to less back and forth trade in the at market price Spread scalping is more difficult and less desirable. The art of spread scalping is predicated on the ease of trading the individual legs of the spread A missed fill in FIFO markets creates opportunity when the market trades back to that price. Pro rata markets offer no such opportunity

Ladder Representation

Impact to CBOT Markets Pro Rata algorithm does not effectively allow for transfer of risk or efficient price discovery when markets are busy Pro Rata algorithm does not reward market participation Pro Rata algorithm limits liquidity, particularly when markets are volatile and liquidity is most needed

FIFO vs. Pro Rata FIFO rewards speed and precision Pro Rata algorithm rewards laggards to the market FIFO better rewards traders that are willing to assume risk, and thereby create liquidity. The CBOT should encourage and reward traders for their timely market participation and contribution to efficient, liquid markets.

GH FV Volume pre and post 7/2 Average daily volume FV 2006 = 54,545 Average daily volume FV post 7/2/06 = 26,599 Percent Change in FV Daily Volume = -34% Average TY to FV ratio 2006 = 1.93 Average TY to FV ratio post 7/2/06 = 2.34 Change in TY to FV = -41% Percent Change in FV Volume for June vs. July Employment = -43%

Competitive Landscape Who does this benefit? What are the costs to liquidity and efficient price discovery? Bund-Bobl spread, a direct competitor to CBOT for trader participation, will benefit Other FIFO product spreads will also benefit as traders shift their focus to FIFO Why leave the door open to Eurex or other exchanges competing for the attention of liquidity providers? Our traders are migrating to CME products because of this change If CBOT is committed to an algorithm rather than a FIFO market in certain products, the exchange must make their algorithm a fair as possible, as soon as possible, or risk losing liquidity

Conclusions GH FV volume is severely impacted by pro rata GH is not unique in how we trade the FV and the FITE GH is moving away from active FV trade TY to FV ratio is growing CBOT markets will become less liquid and less orderly, particularly when markets are active CBOT overall volume will be negatively impacted BOT stock price will fall on decreased volume