I would think so.


Cordially,
Mary Cook
Enron North America Corp.
1400 Smith, 38th Floor, Legal
Houston, Texas   77002-7361
(713) 345-7732 (phone)
(713) 646-3490 (fax)
mary.cook@enron.com



	Tana Jones
	06/01/2001 02:30 PM
		 
		 To: Mary Cook/HOU/ECT@ECT
		 cc: 
		 Subject: (01-184) Reminder on Use of Money Market Funds as Original Margin 
Deposits on the NYMEX Division

Does this apply to us too?
----- Forwarded by Tana Jones/HOU/ECT on 06/01/2001 02:30 PM -----

	exchangeinfo@nymex.com
	05/31/2001 11:30 AM
		 
		 To: tana.jones@enron.com
		 cc: 
		 Subject: (01-184) Reminder on Use of Money Market Funds as Original Margin 
Deposits on the NYMEX Division


Notice # 01-184
May 31, 2001

TO:
All NYMEX Division Members and Member Firms

FROM:
Neal L. Wolkoff, Executive Vice President

RE:
Reminder on Use of Money Market Funds as Original Margin Deposits on the 
NYMEX Division

DATE:
May 31, 2001
===========================================================
This Notice is a reminder regarding certain rule changes and related policy 
guidelines that will go into effect on June 1, 2001 for the NYMEX Division.  
The rule changes going into effect on June 1, 2001 on the NYMEX Division 
allow shares of certain money market mutual funds to be acceptable for 
purposes of original margin deposits.

Corresponding rule changes for the COMEX Division  have also been approved by 
the NYMEX Board of Directors and filed with the CFTC; the changes for the 
COMEX Division will be implemented at a later date.

 Rule Amendments
The amendments generally require that in order to be used for such purpose, a 
money market fund must be approved by the NYMEX Board and also must comply 
with CFTC Regulation o 1.25.  For purposes of original margin, the Exchange,s 
Clearing House will value such money market fund shares at 95% of their 
market value.  In addition, a Clearing Member,s participation in any approved 
fund or any group of approved funds offered by the same issuer shall be 
limited to the greater of $250,000 or 25% of the Clearing Member,s total 
original margin obligations. Finally, no more than 25% of the total assets of 
an approved money market mutual fund may be used to meet original margin 
obligations at the Exchange.

Exchange Policy on Money Market Funds
The NYMEX Board of Directors also recently adopted three additional 
guidelines that will be applicable to such funds. First, until further notice 
from the Exchange, the Board has determined to limit the number of money 
market funds available for this purpose to ten. Second, the Board will 
require that henceforth each fund applying for such status must have a 
minimum value of $5 billion.  Finally, each fund further must provide for 
same day payment if notification is made by 3:00 p.m. on that day.

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 Joseph Sanguedolce, 
Director, Financial Surveillance Section, NYMEX Compliance Department, at 
(212) 299-2855.

AMENDMENTS TO NYMEX RULE 9.05 (&MARGINS8)

(Asterisks indicate additions; brackets indicate deletions.)

Rule 9.05. MARGINS

* * * *
(E) Clearing Members may meet original margin calls by depositing:



*(4) Shares in a money market mutual fund that complies with CFTC Regulation 
o1.25 and that has been approved by the Board, subject to the following 
conditions:

(i) for purposes of original margin, such shares will be valued at 95% of 
market value;
(ii) a Clearing Member,s participation in any approved fund or any group of 
approved funds offered by the same issuer shall be limited to the greater of 
$250,000 or 25% of the Clearing Member,s total original margin obligations;
(iii) no more than 25% of the total assets of an approved money market mutual 
fund may be used to meet original margin obligations at the Exchange.*

[Shares of Brown Brothers Harriman & Co. Common Settlement Fund, valued at 
95% of market value.]



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