From: James Ryan
Sent: February 27, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


Dear Secretary Morris,
My name is James Ryan and I am a member of the Chicago Board of Trade. I became a member in 1974, the same year that the Chicago Board Options Exchange was created. During this time, I was head of clearing operations for Shatkin Trading Company, a major clearing firm at the time. The involvement of Shatkin Trading Company leading up to and after the opening of the Options Exchange was significant. Our primary responsibilities included ensuring that the clearing operations required for the opening of the Exchange were implemented smoothly. I personally spent significant time on this project with the goal of ensuring that the opening of the Options Exchange was a seamless transition, particularly for Shatkin Trading Company and for the overall success of the emerging exchange.
It has always been the understanding of myself and other Board of Trade members, due to the resources we have contributed to the CBOE throughout the years, that we were guaranteed certain membership benefits by the CBOE's Charter. I am writing to encourage you to recognize our efforts in the success of the CBOE, and our rights in maintaining these membership benefits as granted by the CBOE Charter.
Thank you,
James Ryan