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Commodity Futures Trading Commission 

CEA CASES 

NAME: BENEDICT K. GOODMAN 

DOCKET NUMBER: 105 

DATE: FEBRUARY 8, 1962 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Benedict K. Goodman, 

CEA Docket No. 105 

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

Act 

There is reason to believe that the respondent, Benedict K. Goodman, has 

violated the provisions of the Commodity Exchange Act (7 U.S.C. § 1 et seq.), 

hereinafter referred to as the Act, and the rules and regulations issued 

pursuant to its requirements (17 CFR, Chapter 1). In accordance with the 

provisions of section 6(b) of the Act (7 U.S.C. § 9), this complaint and notice 

of hearing is issued stating the charges as follows: 

I 

The respondent, Benedict K. Goodman, is an individual whose address is 636 

Church Street, Evanston, Illinois. At all times during the periods referred to 

in this complaint, he was a member of the Board of Trade of the City of Chicago, 

hereinafter referred to as the Chicago Board of Trade 

II 

The Chicago Board of Trade is now and was at all times during the periods 

referred to in this complaint a duly designated contract market under the 

Commodity Exchange Act. 

III 

At all times during the periods referred to in paragraphs IV through VII of 

this complaint, the respondent owned grain futures accounts carried in his own 

name and grain futures accounts carried in the name of the Library Plaza 

Corporations 636 Church Street, Evanston, Illinois, and all profits or losses 

from the trading in such accounts inured to the respondent. 

IV 

From November 5, 1958, until April 20, 1959, the respondent held, in accounts 

in his own name and in accounts in the name of the Library Plaza Corporation, 

total speculative net long positions in soybean futures on the Chicago Board of 

Trade in excess of 2,000,000 bushels. Such positions ranged from 2,045,000 

bushels to 2,740,000 bushels, and the maximum position of 2,740,000 bushels was 

held continuously from March 18, 1959, through April 7, 1959. By reason 

thereof, the respondent willfully traded in soybeans for future delivery on a 

contract market in amounts which resulted in positions in excess of the maximum 

permissible quantity of 2,000,000 bushels, in violation of § 4a of the Commodity 

Exchange Act (7 U.S.C. § 6a), and the order of the Commodity Exchange Commission 

establishing limits on positions and trading in soybeans for future delivery (17 

CFR § 150.4). 

V 
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From November 5, 1958, through April 20, 1959, the positions in soybean 

futures on the Chicago Board of Trade in accounts owned by the respondent 

exceeded 200,000 bushels in a single future and, 

therefore, the respondent was in a reporting status during such period and was 

required to report to the Commodity Exchange Authority with respect to all 

transactions executed and all positions held during such period for all of his 

accounts in soybean futures, as provided in section 4i of the Act (7 U.S.C. § 

6i), and sections 2.10, 2.11, 2.12, and 2.21 of the regulations issued by the 

Secretary (17 CFR §§ 2.10, 2.11, 2.12, and 2.21). On November 5, 6, 7, 10, 12, 

13, and 19, 1958; January 21, 1959; February 6, 1959; and April 8, 9, 14, 17, 

and 20, 1959, the respondent executed soybean futures transactions in one or 

more of his accounts carried in the name of the Library Plaza Corporation, but 

the respondent filed no reports with respect to such transactions and his 

positions on such dates. By reason of such facts, the respondent willfully 

violated section 4i of the Act (7 U.S.C. § 6i), and sections 2.10, 2.11, 2.12, 

and 2.21 of the regulations issued by the Secretary (17 CFR §§ 2.10, 2.11, 2.12, 

and 2.21). 

VI 

The respondent filed reports with the Commodity Exchange Authority, with 

respect to trading and positions in soybean futures on the Chicago Board of 

Trade in accounts carried in his own name on December 9, 10, 11, 17, 19, 23, 29, 

and 30, 1958; January 9, 14, 15, 16, 19, and 27, 1959; February 2, 3, 4, 5, 10, 

and 17, 1959; March 17, 18, and 24, 1959; and April 1, 6, 7, 10, and 13, 1959, 

but the respondent failed to include in such reports the trading and positions 

in his accounts carried in the name of the Library Plaza Corporation. 

By reason of such facts, the respondent willfully violated section 4i of the Act 

(7 U.S.C. § 6i), and sections 2.10, 2.11, 2.12, and 2.21 of the regulations 

issued by the Secretary (17 CFR §§ 2.10, 2.11, 2.12, and 2.21). 

VII 

From January 12, 1959, until March 19, 1959, the positions in wheat futures 

on the Chicago Board of Trade in accounts owned by the respondent exceeded 

200,000 bushels in a single future and, therefore, the respondent was in a 

reporting status and was required to report to the Commodity Exchange Authority 

with respect to all transactions executed and all positions held during the 

period from January 12, 1959, through March 19, 1959, for all of his accounts in 

wheat futures, as provided in section 4i of the Act (7 U.S.C. § 6i), and 

sections 2.10, 2.11, 2.12, and 2.21 of the regulations issued by the Secretary 

(17 CFR §§ 2.10, 2.11, 2.12, and 2.21). The respondent filed reports with the 

Commodity Exchange Authority, with respect to trading and positions in wheat 

futures on the Chicago Board of Trade in accounts carried in his own name on 

January 12, 13, 16, and 29, 1959; February 5, 16, 17, 26, and 27, 1959; and 

March 3, 4, 5, 6, 9, 10, 12, 16, 17, 18, and 19, 1959, but the respondent failed 

to include in such reports the trading and positions in his accounts carried in 

the name of the Library Plaza Corporation. By reason of such facts, the 

respondent willfully violated section 4i of the Act (7 U.S.C. § 6i), and 

sections 2.10, 2.11, 2.12, and 2.21 of the regulations issued by the Secretary 

(17 CFR §§ 2.10, 2.11, 2.12, and 2.21). 

VIII 

At all times during the periods referred to in paragraphs IV through VII of 

this complaint, the respondent was aware of his obligations under the Act and 

the regulations with respect to speculative position limits and reporting 

requirements. During February 1956, the respondent held speculative positions 

in rye futures on the Chicago Board of Trade which exceeded the maximum 
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permissible limit, and after notification by the Commodity Exchange Authority, 

the respondent brought himself into compliance by reducing such positions. At 

or about the same time, the Commodity Exchange Authority furnished the 

respondent with written information as to the speculative position limits 

applicable to regulated commodities, and notified him that the holding of 

positions in excess of such limits constitutes a violation of the Act. 

IX 

On April 14, 1958, a complaint was filed pursuant to § 6(b) of the Act 

alleging that from December 31, 1957, through February 21, 1958, the respondent 

held total speculative net long positions in the March 1958 rye future, and 

total speculative net long positions in all rye futures combined, on the Chicago 

Board of Trade which resulted in positions in excess of the maximum permissible 

quantity of 500,000 bushels, in violation of § 4a of the Act (7 U.S.C. § 6a), 

and the order of the Commodity Exchange Commission establishing limits on 

positions and trading in rye for future delivery (17 CFR § 150.3). The 

complaint also alleged that from December 31, 1957, through February 21, 1958, 

the respondent was in a reporting status and was required to report to the 

Commodity Exchange Authority with respect to all transactions executed and all 

positions held for his account in all rye futures on all boards of trade during 

such period, and that the respondent bought or sold rye futures on the Chicago 

Board of Trade on 10 days during such period and failed or refused to report 

such purchases and sales and the resulting positions to the Commodity Exchange 

Authority, in violation of § 4i of the Act (7 U.S.C. § 6i), and the rules and 

regulations issued by the Secretary (17 CFR §§ 2.10, 2.11, 2.12, and 2.21). The 

Judicial Officer found that the respondent violated the Act and the regulations, 

as alleged in the complaint, and on October 12, 1959, the Judicial Officer 

issued an order requiring all contract markets to refuse all trading privileges 

to the respondent for a period of 20 days (18 Agric. Dec. 1121 (18 A.D. 1121)). 

On appeal, the order of the Judicial Officer was sustained (Goodman v. Benson, 

286 F. 2d 896 (C. A. 7)). 

THEREFORE, the said respondent, Benedict K. Goodman, is hereby notified to be 

and appear at a hearing to be held at 10:00 a.m. local time, on the 5th day of 

March, 1962, in Chicago, Illinois, at a place to be hereafter designated, before 

a referee designated to conduct such hearing, and then and ther show cause, if 

any there be, why an order should not be made directing that all contract 

markets refuse all trading privileges to the respondent for such period of time 

as may be determined. The respondent will have twenty (20) days after the 

receipt of this notice of hearing in which to file with the Hearing Clerk, 

United States Department of Agriculture, Washington 25, 

D. C., an answer with an original and five 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. 

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

respondent at least twenty (20) days prior to the date set for hearing. 

Done at Washington, D.C., this 

8th day of February, 1962. 

/s/ John P. Duncan, Jr. 

John P. Duncan, Jr. 

Assistant Secretary 
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