November 6, 2000


TO:
ALL NYMEX/COMEX DIVISION MEMBERS
ALL MEMBER FIRMS
ALL CLEARING MEMBERS

FROM: NEAL WOLKOFF

RE: POSITION ADJUSTMENT DEADLINES FOR THE DECEMBER 2000 METAL AND ENERGY 
CONTRACTS [NYMEX RULE 9.04(P) AND COMEX RULE 4.37(A)]

______________________________________________________________________________

As a reminder, position adjustments for both NYMEX and COMEX Division metals 
contracts are prohibited beginning on the tenth business day prior to the 
first business day of the delivery month, and throughout the delivery month.  
Therefore, all position adjustments of concurrent futures positions for the 
December 2000 metals contracts must be completed prior to November 15, 2000.

Additionally, position adjustments of concurrent futures positions for NYMEX 
energy contracts are not permitted during the last three trading days of the 
respective contracts.  Rules 9.04(P) and 4.37(A) are attached.

If you have any questions concerning this matter, please contact Nick Galati 
at (212) 299-2920 or Nick Falcone at (212) 299-2919.

COMEX RULE 4.37A - CONCURRENT FUTURES POSITIONS

(1) Concurrent long and short positions in the current delivery month may not 
be offset by netting, transfer, expit, adjustment or any other bookkeeping 
procedures, but each side must be offset by normal floor transactions in 
accordance with Exchange Rules.  Provided, however, that a clearing member 
will be exempt from this requirement if one side of the concurrent position 
is established the business day prior to the date that the open positions are 
filed with the Clearing House.

(2) For the purposes of this Rule 4.37A, the current delivery month for 
metals futures contracts commences on the open of trading on the tenth (10th) 
business day, prior to the first business day of the delivery month.
The current delivery month for Eurotop futures commences on the open of 
trading on the tenth (10th) business day prior to the termination of the 
respective futures contract, including the termination date.

NYMEX RULE 9.04 - CLEARING PROCEDURE

(P) Concurrent Futures Positions

(1) Concurrent long and short positions in the current delivery month may not 
be offset by netting, transfer, expit, adjustment or any other bookkeeping 
procedures, but each side must be offset by normal floor transactions in 
accordance with Exchange Rules.  Provided, however, that a clearing member 
will be exempt from this requirement if: (I) one side of the concurrent 
position is established the business day prior to the date that the offset 
memoranda are filed with the Clearing House; (II) a clearing member filing 
such offset memoranda can satisfy the Exchange at its request that the delay 
in effecting the offset is attributed to an error in the filing of its 
clearing sheets; and (III) by 10:30 a.m. on the same date that a clearing 
member files such offset memoranda, the clearing member also files with the 
clearing house an updated and accurate Long Open Interest Report.

(2) For the purposes of this Rule 9.04(P), the current delivery month for 
energy futures contracts commences on the open of trading on the third 
business day, prior to termination of the respective futures contract, 
including the termination date.  The current delivery month in platinum and 
palladium commences on the tenth (10th) business day prior to the first 
business day of the delivery month.



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