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Commodity Futures Trading Commission 

CEA CASES 

NAME: CHARLES M. PONOROFF 

DOCKET NUMBER: STIPULATION 127 

DATE: DECEMBER 2, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Charles M. Ponoroff 

Stipulation of Compliance Under the Commodity Exchange Act No. 127 

The Secretary of Agriculture has reason to believe that Charles M. Ponoroff 

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 Charles M. Ponoroff 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 Charles M. Ponoroff 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) Charles M. Ponoroff an individual whose address is 110 N. 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 14, 1969, Charles M. Ponoroff took the opposite side of a 

customer's order for the sale of five contracts of February pork bellies 

noncompetitively without obtaining the prior consent of such customer. The sale 

was made by Charles M. Ponoroff for the account of a customer of Stein-Kohn & 

Company. The opposite side of the transaction was made by Charles M. Ponoroff 

for his own account at Becker Brokerage Co. In connection with this transaction 

Charles M. Ponoroff made false records purporting to show that the transaction 

was made with another floor broker. 

The Commodity Exchange Authority has advised Charles M. Ponoroff that his 

actions as described above, were in violation of section(s) 4b 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 Charles M. Ponoroff 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 
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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 2 day of Dec 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
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