Notice Number:  01-65

February 20, 2001

TO:
ALL COMEX DIVISION MEMBERS

FROM:
M. Dawn Lowe
Vice President and Assistant Corporate Secretary

SUBJECT:
Proposed Amendment to COMEX Rule 4.47, &Position Limits8.


Attached please find a proposed amendment to COMEX Rule 4.47, &Position 
Limits8 which would reduce the maximum number of futures contracts, options 
on such futures contracts, or any combination thereof which any person may 
own or control in the spot month of the Grade 1 Copper Futures Contract from 
2500 to 1500.

The proposed amendment to COMEX Rule 4.47, &Position Limits8 affects a 
&Special Matter8 under the terms of the COMEX By-Laws.  Accordingly, COMEX 
Division Members have ten (10) days to submit a petition signed by owners of 
at least 155 COMEX Division Memberships requesting a vote of the COMEX 
Division Members to disapprove the amendments, pursuant to the procedures set 
forth under COMEX By-Law 205(D).  If a petition is not received, or if the 
amendment is not disapproved, it will be submitted to the Commodity Futures 
Trading Commission (CFTC).

If you have any questions, please contact Dawn Lowe at 212-299-2370, Thomas 
LaSala at 212-299-2897 or Albert J. Getz at 212-299-2608.




Proposed Rule Amendments
(## indicates additions: bracketing indicates deletions)

COMEX Rule 4.47, &Position Limits8

(b) Applicable Limits.  The maximum number of futures contracts, options on 
such futures contracts, or any combination thereof (collectively referred to 
as a "position8) which any person may own or control is as follows:

Commodity  Spot Month Limit*  Net Futures Equivalent Limit

Gold   3000    Subject to Position Accountability

Silver   1500    Subject to Position Accountability

Aluminum   350    Subject to Position Accountability

Copper          [ 2500] ##1500##  Subject to Position Accountability

Eurotop 100
Stock Index  None    10,000

Eurotop 300
Stock Index  None     5,000


*Effective as of the close of business on the second last business day of the 
calendar month preceding the delivery month.

The remainder of COMEX Rule 4.47 remains unchanged.



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