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Commodity Futures Trading Commission 

CEA CASES 

NAME: BUNGE CORPORATION, WALTON F. MULLOY, AND PAUL H. NOVY 

DOCKET NUMBER: STIPULATION 66 

DATE: NOVEMBER 6, 1964 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Bunge Corporation, Walton F. Mulloy, and Paul H. Novy 

Stipulation of Compliance under the Commodity Exchange Act No. 66 

The Secretary of Agriculture has reason to believe that the Bunge 

Corporation, Walton F. Mulloy, and Paul H. Novy have violated the provisions of 

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

Secretary of Agriculture promulgated thereunder. No complaint with respect to 

such violations has been issued and the Bunge Corporation, Walton F. Mulloy, and 

Paul H. Novy are 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, 0.0-0.28). Therefore, the 

Bunge Corporation, Walton F. Mulloy, and Paul H. Novy stipulate the following 

facts are true: 

(1) The Bunge Corporation is and was at all times mentioned herein a 

registered futures commission merchant under the Commodity Exchange Act with an 

office and principal place of business at One Chase Manhattan Plaza, New York 5, 

New York, and a branch office at 300 Southwest Boulevard, Kansas City, Kansas. 

(2) Walton F. Mulloy and Paul H. Novy are and were at all times mentioned 

herein a vice president and the Controller, respectively, of the Bunge 

Corporation. 

(3) The acts and practices on the part of the Bunge Corporation hereinafter 

described were carried out under the supervision and control of respondents 

Walton F. Mulloy and Paul H. Novy in their capacities as a vice president and 

the Controller, respectively, of the Bunge Corporation. 

(4) In letters dated October 31, 1963, addressed to the Kansas City branch 

office and November 4, 1963, addressed to the New York office, the Director of 

the Accounting and Licensing Division of the Commodity Exchange Authority called 

to the attention of Bunge Corporation that an audit of the books of the Kansas 

City office of Bunge Corporation as of August 30, 1963, revealed that on 23 

business days during the audit period such office had failed to compute and keep 

a record showing the amount of money, security, and property owing or accruing 

to its customers which it was required to have in segregated account for such 

customers in order to comply with the requirements of section 4d(2) of the 

Commodity Exchange Act. 

(5) An inspection of the books of the Kansas City branch office of Bunge 

Corporation made as of December 19, 1963, revealed that as of that date such 

office had failed to compute and keep such record for an additional seven 

business days: November 20, December 3, 6, 12, 13, 16, and 17, 1963. 

(6) An audit of the books of the Kansas City branch office of Bunge 

Corporation made as of August 31, 1964, revealed that as of 
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that date such office had failed to compute and keep such record for an 

additional 18 business days: December 31, 1963, January 2 and 13, 1964, February 

13 and 17, 1964, March 9, 1964, April 2, 20, and 23, 1964, June 1, 2, 5, 10, 12, 

16, and 18, 1964, and July 20 and 30, 1964. 

The Bunge Corporation, Walton F. Mulloy, and Paul H. Novy agree to desist 

from such acts and practices in the future. They further understand and agree 

that this stipulation shall be admissible as evidence of such acts and practices 

in any future proceeding based upon acts or practices other than those referred 

to herein which may be brought by the Secretary of Agriculture against any of 

them under the provisions of the said act. They also understand that it is the 

practice of the Commodity Exchange Authority to make stipulations of compliance 

a matter of public record. 

Done at New York, this 6th day of November, 1964. 

BUNCE CORPORATION 

By [SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Paul H. Novy 

Witnesses: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Done at , this 

10 day of Nov. 1964. 

[SEE SIGNATURE IN ORIGINAL] 

Walton F. Mulloy 

Witnesses: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

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