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Commodity Futures Trading Commission 

CEA CASES 

NAME: THOMAS C. WILLIS 

DOCKET NUMBER: 237 

DATE: FEBRUARY 5, 1975 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Thomas C. Willis, Respondent 

CEA Docket No. 237 

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. 1 et seq.), and the regulations issued thereunder (17 CFR 

1.1 et seq.), and therefore this Complaint and Notice of Hearing is issued 

alleging the following: 

I 

Respondent Thomas C. Willis, whose principal place of business is at 175 West 

Jackson Boulevard, Chicago, Illinois 60604, is now, and was at all times 

material herein, a registered floor broker under the Commodity Exchange Act, and 

a clearing member of the MidAmerica Commodity Exchange, a duly designated 

contract market under the Commodity Exchange Act. 

II 

All futures transactions referred to herein relate to wheat and corn futures 

contracts executed in July 1973 by the respondent in his capacity as floor 

broker on the MidAmerica Commodity Exchange for customers of Miller-Lane & 

Company, a registered futures commission 

merchant under the Commodity Exchange Act and a clearing member of the 

MidAmerica Commodity Exchange. Such contracts for future delivery are or may be 

used for (a) hedging any transaction in interstate commerce in such commodity or 

the products or byproducts thereof, or (b) determining the price basis of any 

transaction in interstate commerce in such commodity, or (c) delivering any such 

commodity sold, shipped, or received in interstate commerce for the fulfillment 

thereof. 

III 

Section 4b(D) of the Commodity Exchange Act (7 U.S.C. 6b(D)), in pertinent 

part, prohibits the filling of orders on any contract market "by offset against 

the order or orders of any other person." 

Section 1.39 of the regulations issued pursuant to the Commodity Exchange Act 

(17 CFR 1.39) requires that: 

A member of a contract market who shall have in hand at the same time both 

buying and selling orders of different principals for the same commodity for 

future delivery in the same delivery month may execute such orders for and 

directly between such principals at the market price, if, in conformity with 

written rules of such contract market . . . . 
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(3) Such member executes such orders in the presence of an official 

representative of such contract market designated to observe such transactions 

and, by appropriate descriptive words or symbol, clearly identifies all such 

transactions on his trading card or other similar record, made at the time of 

execution, and notes thereon the exact time of execution and promptly presents 

said record to such official representative for verification and initialing. 

IV 

Rule 406 of the MidAmerica Commodity Exchange, in conformity with Section 

1.39 of the regulations issued pursuant to the Commodity Exchange Act (17 CFR 

1.39), permits the execution of simultaneous buying and selling orders from 

different principals for the same commodity in the same delivery month provided 

that the execution is in the presence of a designated official who shall verify 

and initial the trading card or other record, and the transactions are clearly 

identified, and the time of execution is noted. 

V 

On various dates, specified below, respondent Willis unlawfully offset 

customers' buy and sell orders. He had in hand at the same time both buying and 

selling orders of different principals for the same commodity for future 

delivery in the same delivery month and failed to execute such orders in the 

presence of a designated Exchange official, failed to have such official verify 

and initial respondent's trading card or other record, and failed to identify 

and note on such record the time of execution. 

Offset Trades Made By Thomas C. Willis 

Miller-Lane & 

Co. Customer 

Date Quantity n1 Future Commodity Price Buying Selling 

7/2/73 5 March Corn 203 59093 63062 7/3/73 5 December Corn 202 3/4 61009 80006 

 

7/5/73 10 July Corn 220 28001 10452 

5 December Corn 192 3/4 38034 25025 

n1 Quantities are in '000's of bushels. 

See original document-page 3 

Miller-Lane & 

Co. Customer 

Date Quantity n1 Future Commodity Price Buying Selling 

7/5/73 5 December Corn 194 44020 20014 

5 December Corn 200 20014 44020 

 7/6/73 2 September Corn 202 1/2 54062 11025 

3 September Corn 202 1/2 54062 25017 

1 December Corn 193 5/8 80006 44020 

5 December Corn 194 42030 44042 

4 December Corn 194 7/8 80006 59158 

2 December Corn 194 7/8 59000 59158 

 7/9/73 5 March Wheat 260 1/4 60092 30072 

5 March Wheat 260 1/4 60092 30072 

5 December Corn 196 5/8 59126 10050 

10 December Corn 196 3/4 44020 28001 

 7/10/73 5 March Corn 194 1/2 59126 60065 

1 December Corn 192 33099 18034 

2 December Corn 192 1/2 59093 80006 

1 December Corn 193 7/8 42060 80006 
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 Miller-Lane & 

 Co. Customer 

Date Quantity n1 Future Commodity Price Buying Selling 

7/11/73 2 March Corn 201 1/8 10514 59126 

1 December Corn 200 1/8 60096 10312 

10 December Corn 203 25072 62014 

5 December Corn 203 25043 59078 

2 December Corn 203 25030 59078 

3 December Corn 203 25032 59078 

 7/12/73 10 March Corn 214 28001 27006 

2 September Corn 217 3/4 00222 37016 

2 September Corn 217 3/4 00222 37018 

1 December Corn 206 1/2 80006 26042 

5 December Corn 209 1/4 25090 30012 

1 December Corn 209 1/2 29011 61010 

4 December Corn 211 28040 44020 7/16/73 3 March Wheat 276 1/2 33003 54023 

1 March Wheat 278 1/4 42114 80018 

5 December Wheat 279 20658 59090 

5 December Wheat 282 3/4 50951 60089 7/17/73 5 December Wheat 272 1/2 42116 18035 

1 December Wheat 275 62036 20658 

 7/18/73 5 September Corn 220 3/4 60092 20019 

3 December Corn 213 1/2 18075 80006 

1 December Corn 215 1/2 60096 80006 

10 December Corn 215 1/2 63062 62014 

n1 Quantities are in '000's of bushels. 

See original document-page 4 

Miller-Lane & 

Co. Customer 

Date Quantity n1 Future Commodity Price Buying Selling 

7/18/73 5 December Corn 215 1/2 60073 42114 

2 December Corn 216 63084 62012 

5 December Corn 216 63070 18075 7/20/73 5 September Corn 246 7/8 95011 28040 

10 December Corn 232 1/2 95001 59134 

5 December Corn 233 20019 26044 

1 March Corn 229 1/2 80009 25026 

n1 Quantities are in '000's of bushels. 

VI 

By reason of the facts alleged in this complaint, the respondent has wilfully 

violated section 4b(D) of the Commodity Exchange Act (7 U.S.C. 6b(D)) and 

section 1.39 of the regulations issued thereunder (17 CFR 1.39). 

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, and 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 
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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 the material allegations of fact contained in 

the complaint are admitted, likewise shall constitute a waiver of hearing unless 

a hearing is requested. The respondent is hereby notified that unless such 

hearing is waived, the hearing will be held in Chicago, Illinois, at a place 

therein and date to be specified later, before an Administrative Law Judge 

designated to conduct such hearing. At such hearing, the respondent will have 

the right to appear and show cause, if any there be, why an appropriate order 

should not be issued in accordance with the Commodity Exchange Act (1) 

suspending or revoking the registration of the respondent as a floor broker, (2) 

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 

(3) directing that the respondent shall cease and desist from violating the 

Commodity Exchange Act and regulations in the manner alleged herein. 

Done at Washington, D. C. February 5, 1975 

[SEE SIGNATURE IN ORIGINAL] 

RICHARD L. FELTNER 

Assistant Secretary 

LOAD-DATE: June 16, 2008 
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