Notice No. 01-44
February 01, 2001


TO:       ALL COMEX MEMBERS AND MEMBER FIRMS
ALL COMEX CLEARING FIRMS
ALL COMEX OPERATIONS MANAGERS

FROM:    Neal Wolkoff
Executive Vice President

SUBJECT: REVISED COPPER FUTURES MARGIN RATE CHANGE ON FEBRUARY 2 AND FEBRAURY 
9, 2001, TO AFFECT THE FEBRUARY 2001 CONTRACT ONLY

The following changes are applicable to the February 2001 futures contract 
only.  This notice supercedes the January 31, 2001 notice that previously 
cited increases for both the February and March 2001 futures contracts.

MARGIN RATE CHANGE  FOR FEBRUARY 2, 2001
Effective Date:     Friday, February 2, 2001  (close of business)
Futures Contract:   Copper Futures
Contract Months:    February 2001 Contract Only

COMEX Division Margins on February 2001 Copper Futures Contract
Clearing Member (Maintenance Margin):           Old:  $1,000   New:  $ 3,000
Member Customer (Initial Margin):               Old:  $1,000   New:  $ 3,000
Non-Member Customer (Initial Margin):           Old:  $1,350   New:  $ 4,050

MARGIN RATE CHANGE  FOR FEBRUARY 9, 2001
Effective Date:     Friday, February 9, 2001  (close of business)
Futures Contract:   Copper Futures
Contract Months:    February 2001 Contract Only

COMEX Division Margins on February 2001 Copper Futures Contract
Clearing Member (Maintenance Margin):           Old:  $ 3,000   New:  $ 5,000
Member Customer (Initial Margin):               Old:  $ 3,000   New:  $ 5,000
Non-Member Customer (Initial Margin):           Old:  $ 4,050   New:  $ 6,750

Spread Margins
Current systems calculate the margin requirement for spread positions by 
first determining the "Scan Risk" and then multiplying the number of spreads 
by a rate set by the Exchange.  Scan Risk is determined by netting the 
outright margin required for each leg of a spread.  Note the outright margin 
level required for the February 2001 contract, and all subsequent contracts, 
are different.  Spreading between differently margined contracts results in a 
higher spread margin than between equally margined contracts.  Below are 
margin examples of certain spreads where the legs of the spread are margined 
differently.
Example of Clearing Member Rates for February 2, 2001 Margin Change:
One Long February Copper HG   (1 x $3,000)           =        $   3,000
One Short April Copper HG         (1 x $1,000)           =   -     $   1,000
Net Scan Risk                  ($3,000-$1,000)         =        $   2,000
Spread Rate                   (1x $420)             =   +     $      420
Total Requirement                                 =        $  2,420

COMEX Division Margins on Copper Futures Spreads -
Requirements for Spreads with One Leg in Designated Month
                                    February        Other Months
Clearing Member (Maintenance Margin):         $  2,420           $420
Member Customer (Initial Margin):             $  2,420           $420
Non-Member Customer (Initial Margin):         $  3,267           $567
 Example of Clearing Member Rates for February 9, 2001 Margin Change:
One Long February Copper HG   (1 x $5,000)           =        $  5,000
One Short April Copper HG         (1 x $1,000)           =   -     $  1,000
Net Scan Risk                  ($5,000-$1,000)         =        $  4,000
Spread Rate                   (1x $420)             =   +     $   420
Total Requirement                                 =        $  4,420

COMEX Division Margins on Copper Futures Spreads -
Requirements for Spreads with One Leg in Designated Month
                                    February         Other Months

Clearing Member (Maintenance Margin):         $  4,420           $420
Member Customer (Initial Margin):             $  4,420           $420
Non-Member Customer (Initial Margin):         $  5,967           $567

Should you have any questions regarding these changes, please contact Arthur 
McCoy at (212) 299-2928 or Joe Sanguedolce at (212) 299-2855.  This notice 
supersedes all previous notices regarding outright margins for the COMEX 
Copper Futures Contract.


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