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Commodity Futures Trading Commission 

CEA CASES 

NAME: MICHAEL F. WINNER 

DOCKET NUMBER: STIPULATION 120 

DATE: DECEMBER 15, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Michael F. Winner 

Stipulation of Compliance Under the Commodity Exchange Act No. 120 

The Secretary of Agriculture has reason to believe that Michael F. Winner 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 Michael F. Winner 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 

Michael F. Winner 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) Michael F. Winner an individual whose address is 110 North Franklin 

Street, 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 10, 1969, Michael F. Winner, acting for the account of a 

customer of Imperial Securities, Inc., sold five contracts of March pork bellies 

to Lawrence S. Shepard who was aslo acting for the accounts of customers of 

Imperial Securities, Inc. Such transactions between these two brokers who were 

both qualified to trade for the same clearing member were made with the 

assistance of another floor broker who entered into a wash and accommodation 

transaction with them. 

On February 11, 1969, Michael F. Winner, acting for the account of a customer 

of Imperial Securities, Inc., purchased four contracts of February pork bellies 

from Leonard B. Feldman who was acting for his personal account at Imperial 

Securities, Inc. Such transaction between these two brokers who were qualified 

to trade for the same clearing member was made with the assistance of another 

broker who entered into a wash and accommodation trade with Leonard B. Feldman 

and Michael F. Winner. 
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The Commodity Exchange Authority has advised Michael F. Winner that his 

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

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

Commodity Exchange Act. 

The said Michael F. Winner 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 15 day of December, 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
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