From: Jay Homan
Sent: February 20, 2007
Subject: File No. SR-CBOE-2006-106

My name is Jay Homan and I have been a member of the Chicago Board of Trade ( CBOT) since 1973. I was at the CBOT when the Chicago Board of Options Exchange (CBOE) was formed.

I remember clearly the discussion about whether to create the CBOE as a division of the CBOT much like the International Money Market (IMM) at the Chicago Mercantile Exchange.

The reason that the CBOE was created as a separate entity was to avoid a jurisdictional conflict between the SEC and the CFTC. At all times the intent was to give founding CBOT members an equity stake, either through trading rights or equity distribution.

Best Regards,

Jay Homan