Notice # 01-187
June 1, 2001

TO:
All NYMEX and COMEX Division Members and Member Firms

FROM:
Neal L. Wolkoff, Executive Vice President

RE:
Implementation of Rule Amendments Increasing Capital Requirements for NYMEX 
and COMEX Clearing Members

DATE:
June 1, 2001
===========================================================
Please be advised that the Exchange has determined to implement amendments to
NYMEX Rule 9.21 (&Minimum Capital Requirements8) and to COMEX Clearing 
Association Rule 20 (&Minimum Capital Requirements8), which are attached 
below. The amendments further enhance the financial integrity of the Exchange,
s Clearing Houses by raising the minimum capital requirements applicable to 
all Clearing Members from $2 million to $5 million.  The amendments will go 
into effect on June 30, 2001.

If you have any questions concerning this change, please contact Bernard 
Purta, Senior Vice President, Regulatory Affairs and Operations, at (212) 
299- 2380; Arthur McCoy, Vice President, Financial Surveillance Section, 
NYMEX Compliance Department, at (212) 299-2928; or Charles Bebel, Vice 
President, Clearing Department, at (212) 299-2130.

NYMEX Rule 9.21. MINIMUM CAPITAL REQUIREMENTS

(Additions are indicated by asterisks; Deletions are in {Brackets})

         "(B) Financial Requirements

 Each clearing member registered with the Commission as a futures commission 
merchant shall have and maintain working capital equal to or in excess of the 
greater of {$2,000,000} *$5,000,000* or the amount prescribed in Commission 
Regulation 1.17. Except as provided in Rule 9.02(K), all other Clearing 
Members shall have and maintain minimum working capital of {$2,000,000} 
*$5,000,000*.

CCA Rule 20. MINIMUM FINANCIAL REQUIREMENTS

(Additions are indicated by asterisks; Deletions are in {Brackets})

 (a)(ii) &A Clearing Member must have and maintain at all times an adjusted 
net capital or working capital, as the case may be, of not less than the 
amount set forth in Rule 20(b)( .8
 (b)(I) &For a Clearing Member which is a Futures Commission Merchant 
registered as such with the Commission {and which is a U.S. person,} the 
minimum amount of adjusted net capital shall be {two million ($2,000,000)} 
*$5,000,000* {Dollars}.8
 {(b)(ii) &For a Clearing Member which is a Futures Commission Merchant 
registered as such with the Commission and which is a non-U.S. person, the 
minimum amount of adjusted net capital shall be Two and One Half Million 
($2,500,000) Dollars of which at least One Million ($1,000,000) Dollars ( .8}



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