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Commodity Futures Trading Commission 

CEA CASES 

NAME: UHLMANN & CO., INC., AND CLYDE A. BROWN 

DOCKET NUMBER: STIPULATION 73 

DATE: OCTOBER 29, 1964 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Uhlmann & Co., Inc., and Clyde A. Brown 

Stipulation of Compliance under the Commodity Exchange Act No. 73 

The Secretary of Agriculture has reason to believe that Uhlmann & Co., Inc., 

and Clyde A. Brown have violated the provisions of section 4c(A) of the 

Commodity Exchange Act (7 U.S.C., Chapter 1). No complaint with respect to this 

matter has been issued and Uhlmann & Co., Inc., and Clyde A. Brown 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 Uhlmann & Co., Inc. and Clyde A. 

Brown stipulate that the following facts are true: 

(1) Uhlmann & Co., Inc. is and was at all times mentioned herein, a Delaware 

corporation and a registered futures commission merchant under the Commodity 

Exchange Act with an office and principal place of business at 141 West Jackson 

Boulevard, Chicago, Illinois. It maintains a branch office at 1158 Board of 

Trade Building, Kansas City, Missouri. 

(2) Clyde A. Brown is and was at all times mentioned herein office manager of 

the Kansas City office of Uhlmann & Co., Inc., and a member of the Kansas City 

Board of Trade. 

(3) During the period January 2, 1964, through June 4, 1964, pursuant to 

orders or general instructions given by Uhlmann & Co., Inc., 

various brokers and firms on the Kansas City Board of Trade purchased and sold 

Kansas City wheat futures for the Uhlmann & Co., Inc., Kansas City office house 

account. Such transactions were carried for Uhlmann & Co., Inc. on the books of 

three firms who were clearing members of the Kansas City Board of Trade. The 

purpose of this trading was to afford Uhlmann & Co., Inc. an opportunity to pay 

commissions to the three clearing firms because they had given commodity 

business to Uhlmann & Co., Inc. on other exchanges. During the aforementioned 

period, and pursuant to such orders or general instructions, a total of 

10,750,000 bushels of Kansas City wheat futures were purchased and were sold for 

the account of Uhlmann & Co., Inc. 

(4) The transactions described in paragraph (3) were authorized and directed 

by Uhlmann & Co., Inc. and were carried out under the supervision of Clyde A. 

Brown in his capacity as manager of the Kansas City office of Uhlmann & Co., 

Inc. 

(5) The Secretary of Agriculture has advised Uhlmann & Co., Inc., and Clyde 

A. Brown that such transactions were, or were of the character of, wash or 

fictitious trades in violation of section 4c(A) of the Commodity Exchange Act. 

Uhlmann & Co., Inc. and Clyde A. Brown have agreed to desist from the acts 

and practices set forth in paragraph (3). They understand and agree that this 
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stipulation shall be admissible as evidence of such facts in any subsequent 

proceeding against them or either of them, based upon acts or practices other 

than those referred to herein, which may be brought by the Secretary of 

Agriculture under the provisions of the Commodity Exchange Act, and that it is 

the practice of the 

Commodity Exchange Authority to make stipulations such as this a matter of 

public record. 

Done at Kansas City. Missouri, this 29th day of October, 1964 

UHLMANN & CO., INC. 

By [SEE SIGNATURE IN ORIGINAL] 

Done at Kansas City, Missouri, this 30th day of October, 1964 

[SEE SIGNATURE IN ORIGINAL] 

Clyde A. Brown 

Signature for Uhlmann & Co., Inc. 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Signature of Clyde A. Brown 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

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