The Board of Trade of the City of Chicago and Subsidiaries - Page 12

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          within a 30-day period.  If the membership is not sold within the           
          30-day period, petitioner auctions the membership and remits the            
          proceeds to the seller.  On all these compulsory resales of                 
          memberships, petitioner retains the transfer fee that was paid by           
          the original purchaser and also collects a transfer fee from the            
          new purchaser on the resale.                                                
               In addition to collecting the transfer fees, the Member                
          Services Department collects fees from applicants, members, and             
          others in the following five categories:  (I) Application fees,             
          (ii) delegate fees, (iii) registration fees, (iv) badge fees, and           
          (v) miscellaneous fees.                                                     
               Petitioner's Member Services Department collects application           
          fees in connection with the processing of membership                        
          applications.  From time to time, petitioner's board of directors           
          reconsiders and revises the amount of the application fee.                  
          Increases in the application fee have been related to increases             
          in the cost of operating the CBOT Member Services Department.               
          The application fee for all first time applicants for any type of           
          membership was $750 from January 1, 1988, through December 31,              
          1989, and $1,000 from January 1, 1990, through December 31, 1990.           
          The application fee must be paid, regardless of whether the                 
          purchaser already owns another membership.  However, a person who           
          already owns a CBOT membership submits a short-form application             
          in connection with the acquisition of an additional membership.             





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