Subject: File No. SR-CBOE-2009-087
From: Kannoo Ravindran, Dr
Affiliation: Professor of Finance/CEO

January 14, 2010

Having been a market maker and a pioneer advising insurance companies on risk-management strategies, I strongly feel that the elimination of the minimum volume size required of institutions when executing trades is an excellent initiative since it allows companies to better customize/manage their risks. A consequence of this is that institutions can better manage their counterparty risks. Additionally, the elimination of PM settlement restrictions also help with a more prudent and effective risk-management practice - again allowing hedgers to better and more immediately react to unfavourable market fluctuations.