Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: ARNOLD A. BRIN 

DOCKET NUMBER: STIPULATION 113 

DATE: DECEMBER 3, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Arnold A. Brin 

Stipulation of Compliance Under the Commodity Exchange Act No. 113 

The Secretary of Agriculture has reason to believe that Arnold A. Brin has 

violated the provisions of the Commodity Exchange Act (7 U.S.C., Chapter 1) and 

the regulations of the Secretary of Agriculture promulgated thereunder (17 CFR, 

Chapter 1). No complaint with respect to such violations has been issued and 

the said Arnold A. Brin is desirous of disposing of the matter by entering into 

a stipulation of compliance as authorized by section 0.4(a) of the Rules of 

Practice under the Commodity Exchange Act (17 CFR, Part 0). Therefore, the said 

Arnold A. Brin for the purposes of this stipulation of compliance and 

administrative proceedings under the Commodity Exchange Act and for such 

purposes only, stipulates the following facts are true: 

(1) Arnold A. Brin an individual whose address is 110 N. Franklin St., 

Chicago, Illinois 60606 is now and was at all times material herein a registered 

floor broker under the Commodity Exchange Act and a member of the Chicago 

Mercantile Exchange, a duly designated contract market under the Commodity 

Exchange Act. 

(2) The futures transactions hereinafter referred to relate to pork belly 

futures contracts on the Chicago Mercantile Exchange. Each of such contracts 

called for the delivery of 30,000 pounds of pork bellies. Such contracts could 

have been used for hedging transactions in interstate commerce in pork bellies, 

or for determining 

the price basis of transactions in interstate commerce in pork bellies, or for 

delivering pork bellies, sold, shipped, or received in interstate commerce. 

(3) On February 13, 1969, Arnold A. Brin acting for the account of a customer 

of Reynolds & Company took the opposite side of a portion of the customer's 

order for the purchase of four contracts of March pork bellies noncompetitively 

without obtaining the prior consent of such customer. He took three of the four 

above contracts into his own account at Becker Brokerage Company. Arnold A. 

Brin prepared false records purporting to show that such trade was made with 

another floor broker. 

On February 10, 1969, and again February 17, 1969, Arnold A. Brin assisted 

other floor brokers, qualified for the same clearing member, to execute 

transactions with each other. He entered into wash and accommodation trades 

involving 8 contracts of pork bellies. 

The Commodity Exchange Authority has advised Arnold A. Brin that his actions 

as described above, were in violation of section(s) 4c, 4b and 4g of the 

Commodity Exchange Act and section(s) 1.35 and 1.38 of the regulations under the 

Commodity Exchange Act. 
Page 2 

The said Arnold A. Brin agrees to desist from such acts and practices in the 

future. He further understands and agrees that this stipulation, which the 

Secretary of Agriculture is accepting only as to the acts and practices set 

forth above, shall be admissible as evidence of such acts and practices in any 

future proceeding based upon acts or practices occurring subsequent to the date 

of his signing of this stipulation of compliance which may be brought against 

him by the Secretary of Agriculture under the provisions of the said Act. He 

also understands that it is the practice of the Commodity Exchange Authority to 

issue press releases on stipulations of compliance and to make them a matter of 

public record. 

Done at Chicago, Illinois 

this 3 day of Dec 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
Page 3 
Page 4