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Commodity Futures Trading Commission 

CEA CASES 

NAME: PAUL J. PERLIN 

DOCKET NUMBER: 217 

DATE: NOVEMBER 26, 1973 

DOCUMENT TYPE: DECISION AND ORDER 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Paul J. Perlin, Respondent 

CEA Docket No. 217 

Decision and Order 

Preliminary Statement 

This is an administrative proceeding under the Commodity Exchange Act (7 

U.S.C. Chapter 1, 1970), instituted by a complaint and notice of hearing issued 

on October 2, 1972, under section 6 (c) of the said Act (7 U.S.C. 13b). The 

respondent is charged with violating section 4a of the Commodity Exchange Act (7 

U.S.C. 6a) and section 150.1 of the orders of the Commodity Exchange Commission 

(17 CFR 150.1). 

No hearing has been held in this proceeding. On November 19, 1973, the 

respondent filed a stipulation under section 0.4(b) of the Rules of Practice (17 

CFR 0.4(b)), in which he (1) admits the facts hereinafter set forth in 

paragraphs 1 through 3 of the Findings of Fact, (2) admits, for the purposes of 

this proceeding and for such purposes only, the remaining facts set forth in the 

Findings of Fact and (3) waives hearing on the charges in the complaint and 

consents to the entry, without further proceedings, of the order contained 

herein. 

Findings of Fact 

1. The respondent Paul J. Perlin, an individual whose business address is 

Room 1776, 141 West Jackson Boulevard, Chicago, Illinois 60604, is now, and was 

at all times material herein, a member of the 

Chicago Board of Trade and a partner in the firm of Perlin and Strusiner, a 

clearing member of the Chicago Board of Trade. The respondent is now and was at 

all times material herein a registered floor broker under the Commodity Exchange 

Act. 

2. The Chicago Board of Trade is now, and was at all times material herein, a 

duly designated contract market under the Commodity Exchange Act. 

3. The transactions referred to in the Complaint relate to the purchase and 

the sale of wheat futures contracts on the Chicago Board of Trade. Such 

contracts could have been used for hedging transactions in interstate commerce 

in wheat or the products or byproducts thereof, or for determining the price 

basis of transactions in interstate commerce in wheat, or for delivering wheat 

sold, shipped, or received in interstate commerce. 

4. On or about February 13, 1973, respondent made speculative trades for his 

own account in wheat futures on the Chicago Board of Trade, which were in excess 

of the maximum permissible limits established by the order of the Commodity 

Exchange Commission (17 CFR 150.1), as follows: 
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In Bushels 

Future Purchases Sales 

March 300,000 340,000

May 2,400,000 2,470,000

July 30,000 30,000

 Total 2,730,000 2,840,000 

5. On or about February 14, 1973, the respondent made speculative trades for 

his own account in wheat futures on the Chicago Board of Trade, which were in 

excess of the maximum permissible limits established by the order of the 

Commodity Exchange Commission (17 CFR 150.1), as follows: 

In Bushels 

Future Purchases Sales 

March 140,000 135,000

May 1,930,000 1,930,000

July 100,000 90,000

 Total 2,170,000 2,155,000

6. On or about March 1, 1973, the respondent made speculative trades for his 

own account in wheat futures on the Chicago Board of Trade, which were in excess 

of the maximum permissible limits established by the order of the Commodity 

Exchange Commission (17 CFR 150.1), as follows: 

In Bushels 

Future Purchases Sales 

March 510,000 60,000

May 1,940,000 2,400,000

July 100,000 75,000

 Total 2,550,000 2,535,000

7. On or about March 2, 1973, the respondent made speculative trades for his 

own account in wheat futures on the Chicago Board of Trade, which were in excess 

of the maximum permissible limits established by the order of the Commodity 

Exchange Commission (17 CFR 150.1), as follows: 

See original document-page 3 

In Bushels 

Future Purchases Sales 

March 35,000 35,000

May 1,540,000 1,665,000

July 440,000 340,000

 Total 2,015,000 2,040,000

Conclusions 

By reason of the facts set forth in the Findings of Fact, it is concluded 

that the respondent has violated section 4a of the Commodity Exchange Act (7 

U.S.C. 6a) and section 150.1 of the orders of the Commodity Exchange Commission 

(17 CFR 150.1). The complainant states that the administrative officials of the 

Commodity Exchange Authority have carefully considered the stipulation and the 

terms of the proposed order and they believe that the entry of such order 

without further proceedings would constitute a satisfactory disposition of this 

case, serve the public interest and effectuate the purposes of the Commodity 

Exchange Act. The complainant, therefore, recommends that the stipulation be 

accepted and the proposed order be issued, terminating this proceeding. It is 

concluded that the complainant's recommendation should be adopted. 

Order 

1. Effective immediately, respondent Paul J. Perlin shall cease and desist 

from making speculative trades in futures contracts which are in excess of the 

maximum permissible limits established by the orders of the Commodity Exchange 

Commission. 
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2. A copy of this Decision and Order shall be served on each of the parties 

and on each contract market. 

Done at Washington, D.C. 

NOV 26 1973 

[SEE SIGNATURE IN ORIGINAL] 

Administrative Law Judge 

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