Subject: File No. SR-CBOE-2009-087
From: Ram Kelkar, CFA
Affiliation: FRM - Capital Markets and Trading, Milliman, Inc

January 8, 2010

Life insurance companies are active users of exchange-traded markets to hedge the risks embedded in their liability portfolios. The ability to hedge the risk for smaller notional amounts is vital for small and medium-size insurance companies and for smaller sized liability portfolios for large insurers. FLEX options are an important tool within the hedging tool kit available to life insurers for the purpose of reducing their risk exposures in their liability portfolios, and the ability and flexibility to execute transactions should be enhanced by reducing the minimum size requirements and by allowing PM settlements for all days of the month.