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Commodity Futures Trading Commission 

CEA CASES 

NAME: EDWARD J. KEELEY 

DOCKET NUMBER: STIPULATION 53 

DATE: JULY 12, 1960 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Edward J. Keeley 

Stipulation of Compliance under the Commodity Exchange Act No. 53 

The Secretary of Agriculture has reason to believe that Edward J. Keeley has 

violated the provisions of the Commodity Exchange Act (17 CFR, Chapter 1) by 

virtue of certain transactions in wheat futures as set forth below. 

No complaint with respect to such violation has been issued and the said 

Edward J. Keeley 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, 0.0-0.28). 

Therefore, the said Edward J. Keeley stipulates that the following facts are 

true: 

1. Edward J. Keeley, an individual whose address is 141 West Jackson 

Boulevard, Chicago, Illinois, is now and was at all times mentioned herein a 

registered floor broker under the Commodity Exchange Act and a member of the 

Board of Trade of the City of Chicago, hereinafter called the Chicago Board of 

Trade, a duly designated contract market. 

2. On October 27, 1959, Edward J. Keeley received verbal orders from Merrill 

Lynch, Pierce, Fenner & Smith, Incorporated to sell and buy for the account of a 

customer 105,000 bushels of March wheat on the Chicago Board of Trade as close 

to the same price as possible, to close out and then reinstate the customer's 

position. 

3. Edward J. Keeley executed the above orders on the Chicago Board of Trade 

as follows: 

Bought Sold 

Quantity in Clearing Bushels and Clearing Broker Member Price Member Broker 

Edward J. Keeley Merrill Lynch 25,000 @ $ 2.04 "A" 

 1/2 Edward J. Keeley Merrill Lynch 35,000 @ 2.04 "B" 

 1/2 

Edward J. Keeley Merrill Lynch 5,000 @ 2.04 1/2 "C" 

Edward J. Keeley Merrill Lynch 5,000 @ 2.04 1/2 "D" 

Edward J. Keeley Merrill Lynch 5,000 @ 2.04 1/2 "E" 

Edward J. Keeley Merrill Lynch 5,000 @ 2.04 1/2 "F" 

Edward J. Keeley Merrill Lynch 25,000 @ 2.04 "G" 

 1/2 

 "H" 40,000 @ 2.04 Merrill Lynch Edward J.Keeley

1/2 

"D" 35,000 @ 2.04 " " " " 

1/2 
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Bought Sold 

 Quantity in 

 Clearing Bushels and Clearing 

Broker Member Price Member Broker 

"E" 10,000 @ 2.04 " " " " 

1/2 "I" 5,000 @ 2.04 " " " " 

1/2 "J" 15,000 @ 2.04 " " " " 

1/2 

The Secretary of Agriculture has advised Edward J. Keeley that these were 

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

Edward J. Keeley agrees to desist from such transactions in the future, and 

to refrain from entering into "wash trades". He further understands and agrees 

that this stipulation shall be admissible as evidence of such acts and practices 

in any proceeding based upon transactions in addition to those referred to 

herein which may hereafter be brought by the Secretary of Agriculture against 

him under the provisions of the said act. He also understands that it is the 

practice of the Commodity Exchange Authority to make stipulations of compliance 

a matter of public record. 

Done at Chicago, Illinois, this 

12 day of July 1960. 

/s/ Edward J. Keeley 

Edward J. Keeley 

Witnessed by: 

/s/ Albert W. Kibby 

/s/ Samuel F. Gordon 

LOAD-DATE: June 16, 2008 
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