Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: LOUIS ROMOFF 

DOCKET NUMBER: 166 

DATE: FEBRUARY 17, 1970 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re Louis Romoff, Respondent 

CEA Docket No. 166 

Complaint and Notice of Hearing Under the Commodity Exchange Act 

There is reason to believe that the respondent has violated the Commodity 

Exchange Act (7 U.S.C. Chapter 1, 1964 ed., as amended, Supp. IV, 1969), and the 

regulations made pursuant thereto. In accordance with the provisions of sections 

6(b) and 6(c) of the said Act (7 U.S.C. 9 and 13b, Supp. IV, 1969), this 

complaint and notice of hearing is issued alleging as follows: 

I 

The respondent, Louis Romoff, is an individual whose business address is 3026 

East Vernon, Los Angeles, California 90058. 

II 

The Chicago Mercantile Exchange is now, and was at all times material to this 

complaint, a duly designated contract market under the Commodity Exchange Act. 

III 

(a) On each day during the period from September 1 through October 8, 1969, 

the respondent held open contract positions in live beef cattle futures on the 

Chicago Mercantile Exchange of 25 or more contracts in a single future. 

(b) On each day during the periods from September 24 through October 30, 

1969, and from November 7 through November 11, 1969, the respondent held open 

contract positions in frozen pork belly futures on the Chicago Mercantile 

Exchange of 25 or more contracts in a single future. 

(c) By reason of such positions, the respondent was in reporting status, and 

was required to report to the Commodity Exchange Authority (1) with respect to 

all transactions executed and all open contract positions held for his account 

in all live beef cattle futures on all boards of trade during the period from 

September 1 through October 8, 1969, (2) with respect to all transactions 

executed and all open contract positions held for his account in all frozen pork 

belly futures on all boards of trade during the periods from September 24 

through October 30, 1969, and from November 7 through November 11, 1969, and (3) 

with respect to all such transactions by reason of which the respondent's 

positions were reduced below reporting levels, as provided in section 4i of the 

Commodity Exchange Act (7 U.S.C. 6i, Supp. IV, 1969), and sections 15.01, 15.02, 

15.03, 18.00, 18.01 and 18.03 of the regulations thereunder (17 CFR 15.01, 

15.02, 15.03, 18.00, 18.01 and 18.03). 

IV 

On September 3 and 10, 1969, while the respondent was in reporting status as 

described in paragraph III above, and on October 9, 1969, when the respondent's 
Page 2 

positions in live beef cattle futures were reduced below the reporting level, 

transactions in such futures on the 

Chicago Mercantile Exchange were executed for his account, but the respondent 

failed and refused to submit reports to the Commodity Exchange Authority with 

respect to such transactions, as required under the aforesaid provisions of the 

Commodity Exchange Act and regulations. 

V 

On September 24, 25, 26 and 30, 1969, October 1, 2, 3, 13, 20, 21, 22, 24, 

27, 28, 29 and 30, 1969, and November 7 and 11, 1969, while the respondent was 

in reporting status as described in paragraph III above, and on October 31, 

1969, when the respondent's positions in frozen pork belly futures were reduced 

below the reporting level, transactions in such futures on the Chicago 

Mercantile Exchange were executed for his account, but the respondent failed and 

refused to submit reports to the Commodity Exchange Authority with respect to 

such transactions, as required under the aforesaid provisions of the Commodity 

Exchange Act and regulations. 

VI 

Between June 25, 1968 and August 14, 1969, the Commodity Exchange Authority 

found it necessary to communicate with the respondent on numerous occasions 

because of his failure to transmit reports. On September 24, 1969, the 

Administrator of the Commodity Exchange Authority addressed a letter to the 

respondent calling attention to his delinquencies in submitting reports, and 

advising the respondent that he should file 

all required reports on or before October 10, 1969, and warning him that 

continued failure to file such reports could result in the institution of 

administrative proceedings directed toward the denial of trading privileges on 

all contract markets. Notwithstanding such letter, no reports were filed. In 

the circumstances, the respondent was aware of his obligations under the 

Commodity Exchange Act and regulations with respect to the filing of reports, 

and the failure to submit reports, as required, constituted a knowing and 

willful violation of section 4i of the Commodity Exchange Act (7 U.S.C. 6i, 

Supp. IV, 1969), and sections 15.01, 15.02, 15.03, 18.00, 18.01 and 18.03 of the 

regulations thereunder. 

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

served upon the respondent and this proceeding shall be governed by sections 

0.1, 0.2, 0.4(b), 0.5 through 0.22, and 0.28 of the rules of practice under the 

Commodity Exchange Act (17 CFR 0.1, 0.2, 0.4(b), 0.5 through 0.22, 0.28). The 

respondent 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 three 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 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 this complaint are admitted likewise shall constitute a waiver 

of hearing unless a hearing is requested. The respondent is hereby notified 

that unless a hearing is waived, a hearing will be held at 10:00 a.m., local 

time, on April 8, 1970, in Los Angeles, California, at a place therein to be 

specified later, before a referee designated to conduct such hearing. At such 

hearing, the respondent will have the right to appear and show cause, if any 
Page 3 

there be, why an appropriate order should not be issued in accordance with the 

Commodity Exchange Act, (1) prohibiting the respondent from trading on or 

subject to the rules of any contract market, and directing that all contract 

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

as may be determined, and (2) directing that the respondent shall cease and 

desist from violating the Commodity Exchange Act in the manner alleged herein. 

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. 

February 17, 1970 

[SEE SIGNATURE IN ORIGINAL] 

Richard E. Lying 

Assistant Secretary 

LOAD-DATE: June 16, 2008 
Page 4