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Commodity Futures Trading Commission 

CEA CASES 

NAME: BACHE & CO. INCORPORATED, HAROLD L. BACHE, AND ROBERT C. HALL 

DOCKET NUMBER: 147 

DATE: OCTOBER 13, 1967 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Bache & Co. Incorporated, Harold L. Bache, and Robert C. Hall, 

Respondents 

CEA Docket No. 147 

Complaint and Notice of Hearing Under Section 6(b) of the Commodity Exchange 

Act 

There is reason to believe that the respondents, Bache & Co. Incorporated, 

Harold L. Bache and Robert C. Hall, have violated the Commodity Exchange Act (7 

U.S.C. 1 et seq.) and the regulations made pursuant thereto (17 CFR, Part I), 

and in accordance with the provisions of section 6(b) of the said act (7 U.S.C. 

9), this complaint and notice of hearing is issued stating the charges in that 

respect as follows: 

I 

Respondent Bache & Co. Incorporated is now and was at all times when it is 

mentioned herein a Delaware corporation with its principal office and place of 

business at 36 Wall Street, New York, New York, and a registered futures 

commission merchant under the Commodity Exchange Act. The said corporation is 

the successor of Bache & Co., a dissolved partnership. Substantially all of the 

assets of the said partnership were transferred to and its liabilities assumed 

by respondent Bache & Co. Incorporated on January 31, 1965. At all times 

material herein through January 31, 1965, the said partnership 

was a registered futures commission merchant under the Commodity Exchange Act 

with its principal office and place of business at 36 Wall Street, New York, New 

York. 

II 

Respondent Harold L. Bache, an individual whose business address is 36 Wall 

Street, New York, New York, was at all times material herein through January 31, 

1965, the directing partner of Bache & Co., the partnership, and is now and was 

at all times material herein subsequent to January 26, 1965, Chairman of the 

Board of Directors and Chief Executive Officer of respondent Bache & Co. 

Incorporated. 

III 

Respondent Robert C. Hall, an individual whose business address is 36 Wall 

Street, New York, New York, was at all times material herein through January 31, 

1965, a general partner in Bache & Co., the partnership, and is now and was at 

all times material herein subsequent to January 26, 1965, Treasurer and Vice 

President of respondent Bache & Co. Incorporated. 

IV 
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The operations and transactions of the respondent corporation, hereinafter 

described, were ordered and directed by, or carried out under the supervision 

and control of, respondent Harold L. Bache and respondent Robert C. Hall, acting 

in their capacities as officers of the respondent corporation. 

V 

At all times between May 2, 1966, and September 3, 1966, the respondent 

corporation, acting in its capacity as futures commission merchant, carried 

accounts for customers who traded in commodity futures subject to the provisions 

of the Commodity Exchange Act and regulations, and had to its credit with banks, 

or other depositories, money and securities in varying amounts, held in 

segregated accounts and identified as customers' funds, representing deposits of 

margin by and trading profits belonging to such customers. 

VI 

Under the regulations issued pursuant to the Commodity Exchange Act the 

respondent corporation was obligated during the period specified in paragraph V 

to prepare and maintain a daily computation and record setting forth the amount 

of money, securities and property of its customers required to be held, and 

held, in segregated accounts in accordance with the requirements of section 

4d(2) of the Commodity Exchange Act (7 U.S.C. 6d(2)). According to the daily 

computation and record that was prepared and kept by the respondent corporation 

to meet the requirements of the regulations, on sixteen (16) business days 

between May 2, 1966, and September 3, 1966, to wit, May 3, 4, 6, 9, 10, 11, July 

13, 15, 18, 19, 25, 29, August 1, 3, 31 and September 2, the respondent 

corporation was under-segregated in amounts ranging from $ 10,710.03 on July 25 

to $ 832,412.94 on July 13 -- that is, the total amount of customers' money, 

securities and property held in segregated accounts as set forth in 

paragraph V was, according to the respondent corporation's daily computation and 

record, insufficient, by such amounts, to pay all credits and equities due to 

such customers. 

VII 

The daily computation and record prepared and maintained by the respondent 

corporation for each business day between August 3, 1966, and August 27, 1966, 

show that the respondent corporation had excess funds in segregation on each 

such day. However, such computations and records contain errors which as of 

August 26, 1966, result in an overstatement thereon of the amount of customers' 

money, securities and property held in segregation in relation to the amount 

required to be so held, in an amount in excess of $ 800,000. The principal 

errors causing such overstatement and the date each such error was first made 

are set forth in the tabulation, marked Exhibit A, attached hereto and made a 

part hereof. The aforementioned daily computations and records of the 

respondent corporation, when adjusted to compensate for such errors, show that 

on twelve (12) business days between August 3, 1966, and August 27, 1966, to 

wit, August 4, 11, 12, 15, 16, 17, 18, 19. 22, 23, 24 and 25, the respondent 

corporation was under-segregated in amounts ranging from $ 16,631.83 on August 4 

to $ 711,958.14 on August 23 -- that is, the total amount of customers' money, 

securities and property held in segregated accounts as set forth in paragraph V 

was, according to the daily computation and record when so adjusted, 

insufficient, by such amounts, to pay all credits and equities due to such 

customers. 

VIII 

Examination of the records of Bache & Co., the partnership, by the Commodity 

Exchange Authority as of October 27, 1961, August 31, 1962 and August 23, 1963, 

disclosed that the firm had not satisfactorily complied with the requirements of 

the Commodity Exchange Act and the regulations thereunder relating to the 
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handling of customers' funds and to the preparation and maintenance of records 

in connection therewith. These matters were called to the attention of Bache & 

Co. and on February 18, 1964, the Administrator of the Commodity Exchange 

Authority wrote a letter to respondent Harold L. Bache as follows: 

Our most recent audit of Bache & Co., conducted as of August 23, 1963, 

disclosed serious deficiencies on the part of your firm. 

When our accountants started the audit they found that your records indicated 

undersegregation on 13 days in amounts ranging up to almost $ 350,000. In a 

number of instances undersegregation was indicated for several days before being 

corrected. Inasmuch as the segregation requirements of the act and regulations 

were discussed with partners of your firm after previous audits, I am disturbed 

to find from this latest audit that when your own records indicated an 

undersegregated condition, remedial action was not immediately taken. 

On July 1, 1963, I wrote you calling your attention to the continuing failure 

of your firm to meet the reporting requirements under the act. While the last 

audit reveals improvement with regard to the '00 series reports, it also reveals 

that serious deficiencies continue with regard to the '01 series reports. In 

'01 reports submitted for August 23, for example, your firm made 22 errors in 

reporting customers' positions. In 12 of these cases, positions were reported 

for individuals who had completely closed out such positions before that date. 

Our examination revealed that recordkeeping inadequacies on the part of your 

firm were so numerous as to make your segregation record unreliable for 

determining whether there was compliance with the segregation provisions of the 

act and regulations. We do not find at other firms of comparable size to yours 

the recordkeeping deficiencies that we find at Bache & Co. We cannot continue 

to accept such records as constituting compliance with the recordkeeping 

requirements of the act and regulations. 

The purpose of this letter is to call again to your attention the failure of 

Bache & Co. to observe the segregation, reporting and recordkeeping requirements 

of the act and regulations. As I advised you in my letter of July 1, 1963, the 

continued failure of your firm to comply with the provisions of the statute and 

regulations could lead to the issuance of a complaint looking toward revocation 

or suspension of your registration as a futures commission merchant. 

I would appreciate hearing from you regarding steps you are taking to achieve 

continuing compliance with the provisions of the act and regulations. 

In a letter dated February 19, 1964, respondent Harold L. Bache wrote the 

Administrator as follows: 

I have your letter of February 18th in regard to the undersegregation which 

has been discussed with you last August and, it is my understanding, has been 

completely cleared up. 

We have made a thorough reorganization of our accounting program and moved 

its supervision into strong hands. 

We are sure that we are in splendid condition. 

Mr. Tessler, who is in charge of our operations in the Commodity Department, 

receives a daily report showing oversegregation. 

I am, however, instructing our Treasurer to make an immediate study of this 

situation, and upon my receipt of his report, you will hear further from me. 

Thank you for drawing this matter to my attention. We feel we have a good 

accounting operation now. 

In a letter dated March 18, 1964, respondent Robert C. Hall wrote the 

Administrator as follows: 

Referring to Mr. Bache's letter of February 19, 1964, in which he stated that 

he was instructing the Treasurer to make an immediate study of the situation 
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which was invited to our attention in your letter of February 18, I am pleased 

to report as follows: With reference to the under-segregated condition outlined 

in paragraph 2 of your letter, kindly be advised that we have taken the 

following action: 

1) Instituted a system of cross-check to verify the figures comprising the 

daily C.E.A. segregation requirements. 

2) Formalized our C.E.A. segregated fund reporting structure by establishing 

a flow of daily copies of written reports to both the Treasurer and the Partner 

in Charge of the Commodity Division. 

3) Increased our minimum oversegregated fund base from $ 300,000 to $ 

400,000. 

With reference to reporting requirements under the Act, as you know earlier 

this year the Commodity bookkeeping function was transferred to our Operations 

Division to consolidate all operations under one responsible partner. 

Additional staff has been retained and existing staff upgraded and we have 

achieved much better coordination between our New York and out of town office 

commodity reporting. 

During this calendar year all of our commodity bookkeeping functions will be 

placed on the computer in stages, which will greatly simplify our reporting 

procedures and improve the accuracy of such reports. We therefore feel that the 

reporting requirements under the Act will be fulfilled in an increasingly 

effective manner. 

By the same token we believe that the steps that we have instituted as we 

have outlined above will make our record keeping accurate at all times so that 

our segregation record will be reliable and we will be able to comply strictly 

with the segregation requirements under the Act. 

We look forward to your next examination and hope that you will be fully 

satisfied with the remedial action which we have taken. 

Examination of the records of Bache & Co. by the Commodity Exchange Authority 

as of June 26, 1964, again disclosed that the firm had not satisfactorily 

complied with the requirements of the Commodity Exchange Act and the regulations 

relating to the handling of customers' funds and to the preparation and 

maintenance of records in connection therewith. On November 18, 1964, 

representatives of the Commodity Exchange Authority called these matters to the 

attention of representatives of Bache & Co., including respondent Robert C. 

Hall, and they assured the representatives of the Commodity Exchange Authority 

that necessary corrective measures would be taken. 

IX 

By reason of the facts described in this complaint, the respondents wilfully 

violated sections 4d(2) and 4g of the Commodity Exchange Act (7 U.S.C. 6d(2), 

6g), and sections 1.20, 1.23, 1.32 and 1.35 of the regulations thereunder (17 

CFR 1.20, 1.23, 1.32, 1.35). 

WHEREFORE, it is hereby ordered that this complaint and notice of hearing be 

served upon the said respondents. The respondents will have twenty (20) days 

after the receipt of this complaint in which to file with the Hearing Clerk, 

United States Department of Agriculture, Washington, D. C. 20250, an answer with 

an original and four copies, fully and completely stating the nature of the 

defense and admitting or denying, specifically and in detail, each allegation of 

this complaint. Allegations not answered will be deemed admitted for the 

purpose of this proceeding. Failure to file an answer will constitute an 

admission of all the allegations of this complaint and a waiver of hearing. The 

filing of an answer in which all of the material allegations of fact contained 

in the complaint are admitted likewise shall constitute a waiver of hearing 

unless a hearing is requested. The respondents are hereby notified that unless 

hearing is waived, a hearing will be held at 10:00 a.m., local time, on November 
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15, 1967, in New York, New York, at a place therein to be specified later, 

before a referee designated to conduct such hearing. At such hearing the 

respondents will have the right to appear and show cause, if any there be, why 

an order should not be made suspending or revoking the registration of 

respondent Bache & Co. Incorporated as futures commission merchant, and 

directing that all contract markets refuse all trading privileges to each 

respondent for such period of time as may be determined. 

It is ordered that this complaint and notice of hearing be served on each of 

the said respondents at least twenty (20) days prior to the date set for 

hearing. 

Done at Washington, D. C. 

OCT 13 1967 

[SEE SIGNATURE IN ORIGINAL] 

Acting Assistant Secretary 

EXHIBIT A 

BACHE & CO. INCORPORATED 

PRINCIPAL ERRORS AFFECTING THE AMOUNT OF MONEY, SECURITIES AND PROPERTY HELD 

IN SEGREGATED ACCOUNT IN RELATION TO THE AMOUNT REQUIRED TO BE SO HELD IN ORDER 

TO COMPLY WITH SECTION 4d(2) OF THE COMMODITY EXCHANGE ACT, AS REVEALED BY 

EXAMINATION AS OF AUGUST 26, 1966 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1965 

1 Dec. 2 Improper entry in segregated ($ 635.00) 

funds bank ledger account No. 99 23151. 

1966 2 March 3 Securities shown as being on (50,000.00) deposit with the New York Produce Exchange Clearing 

Association when such was not 

the case. 3 April 4 Transfer of funds from (70,000.00) 

segregated funds account in bank No. 10154 not shown in 

segregated funds bank ledger 

account. 

4 April 25 Disbursement from segregated (518.20) 

funds account in bank No. 61151 not shown in segregated 

funds bank ledger account. 

 5 April 26 Disbursement from segregated (362.50) 

funds account in bank No. 

61151 not shown in segregated funds bank ledger account. 
Page 6 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 

6 May 11 Deposit in segregated funds $ 362.10 account in bank No. 61151 not shown in segregated funds 

bank ledger account. 7 June 1 Deposit in segregated funds 15,000.00 account in bank No. 29151 not shown in segregated funds 

bank ledger account. 

 8 June 17 Improper entry in segregated 

funds bank ledger account 

series, account No. 99 72152. (800.00) 

9 June 29 Improper entry in segregated (1,000.00) funds bank ledger account No. 99 12151. 

10 June 30 Improper entry in segregated (400.00) funds bank ledger account No. 

99 23151. 

 11 July 1 Deposit in segregated funds 900.00 

account in bank No. 29151 not 

recorded in segregated funds bank ledger account. 

 12 July 11 Deposit in segregated funds 5,000.00 account in bank No. MR 151 

not recorded in segregated funds bank ledger account. 

13 July 15 Regulated commodity interbank (11,000.00) clearance account No. 99 SB 296 overstated. 

 

14 July 20 Deposit in segregated funds 4,700.00 account in bank No. MH 151 

not recorded in segregated 

funds bank ledger account. 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 15 July 21 Deposit in segregated funds $ 642.00 

account in bank No. 59154 not 

recorded in segregated funds bank ledger account. 

 

16 July 25 Deposit in segregated funds 17,214.85 account in bank No. 54153 not 

recorded in segregated funds 
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 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 bank ledger account. 17 July 26 Deposit in segregated funds 1,000.00 

account in bank No. 17151 not shown in segregated funds bank ledger account. 18 July 26 Improper entry in segregated (3,550.00) funds bank ledger account No. 99 17151. 

 19 July 26 Deposit in segregated funds 1,975.00 

account in bank No. MH 151 

not shown in segregated funds bank ledger account. 

 20 July 26 Transfer of funds from (50,000.00) segregated funds account in 

bank No. 40151 not shown in 

segregated funds bank ledger account. 

 21 July 28 Disbursement from segregated (500.00) funds account in bank No. 

43151 not shown in segregated 

funds bank ledger account. 

22 July 28 Regulated commodity interbank (25,000.00) clearance account No. 99 38296 overstated. 

 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 

23 July 29 Transfer of funds from ($ 16,000.00) 

segregated funds account in bank No. PX152 not shown in segregated funds bank ledger account. 24 July 29 Improper entry in regulated 40,000.00 commodity interbank clearance account No. 99 23296. 

25 Aug. 1 Segregated funds bank ledger 1,202.50 account No. 97 10164 not 

included in preparing segregation record. 

26 Aug. 1 Deposits in segregated funds 66,000.00 

account in bank No. 99155 not recorded in segregated funds bank ledger account. 
Page 8 

 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 27 Aug. 1 Improper entry in segregated 31,600.00 funds bank ledger account No. 99 41152. 

 28 Aug. 3 Transfer of funds from (153,084.00) 

segregated funds account in bank No. 64159 erroneously treated as a deposit in the 

segregated funds bank ledger account for that bank. 

29 Aug. 3 Improper entry in ledger 76,542.00 account No. 99 46159, a segregated funds bank account 

series. 

 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 30 Aug. 3 Deposit in segregated funds $ 15,000.00 account in bank No. 99155 not 

recorded in segregated funds bank ledger account. 

31 Aug. 3 Regulated commodity (55,000.00) 

interbank clearance account No. 99 09296 overstated. 

32 Aug. 3 Regulated commodity interbank (5,000.00) clearance account No. 99 

41296 overstated. 33 Aug. 3 Deposit in segregated funds 1,500.00 

account in bank No. 51151 

not recorded in segregated funds bank ledger account. 34 Aug. 3 Deposit in segregated funds 2,800.00 account in bank No. 05154 

not recorded in segregated funds bank ledger account. 

35 Aug. 4 Transfer of funds from (80,000.00) 

segregated funds account in bank No. 23151 erroneously 

treated as deposit in the 

ledger account for that bank account. 

36 Aug. 4 Deposit in segregated funds 4,750.00 account in bank No. MH151 

not recorded in segregated 
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 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 funds bank ledger account. 37 Aug. 4 Failure to make proper entry ( 667,676.87) 

in segregated funds bank ledger account No. 99 99155. 38 Aug. 5 Deposit in segregated funds 300.00 account in bank No. 36159 not recorded in segregated 

funds bank ledger account. 

 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 

39 Aug. 8 Transfer of funds from ($ 12,000.00) segregated funds account 

in bank No. 43151 not shown 

in segregated funds bank ledger account. 

 

40 Aug. 8 Disbursement from segregated (600.00) funds account in bank No. 

06151 not recorded in segre- gated funds bank ledger account. 

 41 Aug. 8 Credit entry in ledger $ 55,836.31 account No. 96 00311 not 

included when totalling 

customers' ledger balances for the segregation records. 

 42 Aug. 9 Transfer of funds from (30,000.00) segregated funds account in 

bank No. PL 152 not recorded 

in segregated funds bank ledger account. 43 Aug. 10 Deposit in segregated funds 3,000.00 account in bank No. MH151 

not recorded in segregated funds bank ledger account. 

44 Aug. 10 Deposit in segregated 2,800.00 

funds account in bank No. MH151 not recorded in 

segregated funds bank 

ledger account. 45 Aug. 11 Deposit in segregated 2,300.00 

funds account in bank No. MH151 not recorded inseg- regated funds bank ledger 
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 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 account. 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 

46 Aug. 11 Deposit in segregated $ 26,952.22 funds account in bank No. 54153 not recorded 

insegregated funds bank ledger account. 47 Aug. 15 Deposit in segregated 1,579.00 funds account in bank No. 

54153 not recorded in segregated funds bank ledger account. 

 48 Aug. 15 Regulated commodity (3,600.00) interbank clearance account 

No. 99 81296 overstated. 

 49 Aug. 16 Deposit in segregated funds 2,750.00 

account in bank No. 54153 

not recorded in segregated funds ledger account. 

 50 Aug. 16 Improper entry in segregated 17,214.85 funds bank ledger account 

No. 99 54153. 

 51 Aug. 18 Regulated commodity (60,000.00) interbank clearance account 

No. 99 07296 overstated. 52 Aug. 18 Deposit in segregated funds 4,400.00 

account in bank No. MH151 not recorded in segregated funds bank ledger account. 53 Aug. 18 Improper entry in segregated (10,777.75) 

funds bank ledger account No. 99 61151. 

54 Aug. 18 Value of U.S. Treasury Bills (15,897.61) 

purchased with custmers' funds and shown on the 

segregation record 

overstated. 55 Aug. 18 Value of New York City (46,600.00) 

General Obligation Bonds purchased with customers' funds and shown on the 
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 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 segregation record overstated. 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 56 Aug. 19 Improper entry in segregated ($ 10,000.00) 

funds bank ledger account 

No. 99 32152. 

57 Aug. 19 Fluctuation, from previous (21,710.00) day's overstatement, in the value of U.S. Treasury Bills purchase with customers' 

funds 

58 Aug. 19 Fluctuation, from previous (2,700.00) day's overstatement, in the value of NYC General Obligation Bonds purchased 

with customers' funds 59 Aug. 22 Disbursement from segregated (25,000.00) funds account in bank No. 17151 not shown segregated 

funds bank ledger account. 

 60 Aug. 22 Deposit in segregated funds 3,000.00 

account in bank No. 32152 

not recorded in segregated funds bank ledger account. 

 61 Aug. 22 Fluctuation, from previous 21.53 day's overstatement, in the 

value of NYC General 

Obligation Bonds purchased with customers' funds. 62 Aug. 22 Fluctuation, from previous (600.00) day's overstatement, in the 

value of NYC General Obligation Bonds purchased with customers' funds. 

 63 Aug. 22 Value of U.S. Treasury Bills 389,380.00 purchased with customers' 

funds not shown on segregation record. 

Amount 

Increase (or Increase (or 
Page 12 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 

64 Aug. 23 Overstatement in segregated $ 1,200.00 funds bank ledger account No. 99 23151 of funds 

withdrawn. 65 Aug. 23 Fluctuation, from previous 1,155.98 

day's overstatement, in the value of U.S. Treasury Bills purchased with customers' 

funds. 

66 Aug. 23 Fluctuation, from previous (1,400.00) 

day's overstatement, in the value of NYC General 

Obligation Bonds purchased 

with customers' funds 

67 Aug. 24 Improper entry in segregated 4,808.00 funds bank ledger account No. 99 17151. 

68 Aug. 24 Improper entry in segregated (700.00) funds bank ledger account 

No. 99 29151. 

 69 Aug. 24 Disbursement from segregated (1,869.20) 

funds account in bank No. 

52151 not shown in segregated funds bank ledger 

account. 70 Aug. 24 Deposit in segregated funds 840.00 account in bank No. MH151 

not recorded in segregated funds bank ledger account. 

 

71 Aug. 24 Erroneous entry in regulated (60,000.00) commodity interbank 

clearance account No. 99 07296. 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 72 Aug. 24 Regulated commodity interbank ($ 10,000,00) 

clearance account No. 99 08296 overstated. 

73 Aug. 24 Fluctuation, from previous 155.55 

day's overstatement, in the value of U.S. Treasury Bills purchased with customers' 

funds. 74 Aug. 24 Fluctuation, from previous (2,000.00) 
Page 13 

 Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 day's overstatement, in the value of NYC General Obligation Bonds purchased 

with customers' funds. 75 Aug. 24 Fluctuation, from previous 60.00 

day's overstatement, in the value of U.S. Treasury Bills purchased with customers' 

funds. 76 Aug. 25 Improper entry in segregated (24,460.58) 

funds bank ledger account 

No. 99 38152. 

77 Aug. 25 Fluctuation, from previous 419.44 day's overstatement, in the value of U.S. Treasury Bills purchased with customers' 

funds. 

78 Aug. 25 Fluctuation, from previous (1,300.00) day's overstatement, in the value of NYC General Obligation Bonds purchased 

with customers' funds. 79 Aug. 25 Fluctuation, from previous 98.89 day's overstatement, in the value of U.S. Treasury Bills 

purchased with customers' 

funds. 

Amount 

Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

Segregation Segregation 

Provided Needed 

1966 80 Aug. 26 Regulated commodity interbank ($ 8,000.00) 

clearance account No. 99 

04296 overstated. 

81 Aug. 26 Regulated commodity interbank (25,000.00) clearance account No. 99 DV296 overstated. 

82 Aug. 26 Improper entry in segregated (7,375.83) funds bank ledger account 

No. 99 99155. 83 Aug. 26 Fluctuation, from previous 59.73 

day's overstatement, in the 

value of U.S. Treasury Bills purchased with customers' 

funds. 
Page 14 

 Amount 

 Increase (or Increase (or 

Item No. Date Description of Error Decrease) in Decrease) in 

 Segregation Segregation 

 Provided Needed 

 1966 84 Aug. 26 Fluctuation, from previous (5,000.00) day's overstatement, in the value of NYC General 

Obligation Bonds purchased with customers' funds. 

85 Aug. 26 Fluctuation, from previous 21.11 day's overstatement, in the value of U.S. Treasury Bills 

purchased with customers' funds. 

86 Aug. 26 The balance of regulated ($ 54,752.80) customers' accounts in 

deficit overstated on segregation record prepared as of August 26, 1966. 87 Aug. 26 Regulated commodity contract (575.00) difference accounts out of 

balance. 

 

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