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Commodity Futures Trading Commission 

CEA CASES 

NAME: PAUL J. PERLIN 

DOCKET NUMBER: 217 

DATE: OCTOBER 2, 1973 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Paul J. Perlin Respondent 

CEA Docket No. 217 

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 made pursuant thereto, and 

this complaint and notice of hearing is issued stating the charges in that 

respect as follows: 

I 

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

1770, 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 & 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. 

II 

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

duly designated contract market under the Commodity Exchange Act. 

III 

The transactions referred to in this complaint relate to the purchase and 

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 by products 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. 

IV 

a. 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: 

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

b. 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 
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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 

c. 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

d. 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: 

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

V 

By reason of the facts alleged in this complaint, the respondent 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). 

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 Practices under the 

Commodity Exchange Act (17 CFR 0.1, 0.2, 0.4(b), 0.5 through 0.22, 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 purposes of this proceeding. Failure 

to 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 of 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 hearing is waived, a hearing will be 

held in Chicago, Illinois, at a place therein and date to be specified later, 

before a 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, 

directing that the respondent shall cease and desist from violating the Act and 

regulations in the manner alleged herein. 
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It is ordered that this complaint and notice of hearing be served on the 

respondent at least twenty (20) days prior to the date set for hearing. October 

2, 1973. 

Done at Washington, D. C. 

CLAYTON YEUTTER 

Assistant Secretary 

LOAD-DATE: June 12, 2008 
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