RE: FILE No. SR-CBOE-2006-106
Nancy M. Morris
Secretary, Securities and Exchange Commission 100 F. Street, NE Washington, DC 20549-1090
Dear. Ms. Morris:
My name is Bryan Cournoyer and I am strongly opposed to the proposed rule change.
Prior to my purchase of a full CBOT seat in 2001 I was leasing a full membership at rates as high as $8000 per month. This rate reflected the right to exercise a membership at the CBOE. I was willing to pay this amount in part because of that right. When I purchased my CBOT membership I had to borrow money from the bank in order to finance this purchase, they in turn recognised this potential value in determining their risk factor for the loan. So at the time of my purchase the membership included the exercise right to the CBOE , they were recognised by the bank, the CBOT and the CBOE and now those rights are wrongly being taken away by the CBOE with their rule change. I would urge you to consider this factor in your decision and therefore disallow this rule change.
Respectively: Bryan Cournoyer