February 26, 2007
I am writing you relative to the recent filing by The Chicago Board Of Options Exchange. There are a number of items which concern me which I feel are unfair and unreasonable. I have been a full member of the Chicago Board Of Trade since 1975. When I initially became a member, considerable money, time, and development was provided by C.B.O.T. to develop the options business. We were the reason the C.B.O.E. exists today. As a member at C.B.O.T. we have been advised hold contractual and legal equity in The Chicago Board of Options. It is my understanding that the charter of C.B.O.E. article fifth (b) outlines and provides for provisions to fill C.B.O.T. members. The history of trading privileges at C.B.O.E. for C.B.O.T. full memberships seems to speak for the relationship guide clearly. The proposal rule change by The Chicago Board Of Options in my opinion is another attempt to enhance their economic situation and disregard the commitments and contractual obligation they have made previously. The C.B.O.E. has made previous attempts to negate their due obligation in several cases of previous verbage. What are the grounds and viability for the proposal rule change? I am requesting your agency to respond based on what is fair and just. I have always believed my interests in The Chicago Board of Options to be a legal and contractual asset. If there is any question relative to the legal and / or contractual aspects, it should be resolved in the United States legal system not otherwise.
Thank you for your consideration
Harlan R. Krumpfes