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Commodity Futures Trading Commission 

CEA CASES 

NAME: LAWRENCE S. SHEPARD 

DOCKET NUMBER: STIPULATION 132 

DATE: DECEMBER 14, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Lawrence S. Shepard 

Stipulation of Compliance Under the Commodity Exchange Act No. 132 

The Secretary of Agriculture has reason to believe that Lawrence S. Shepard 

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 Lawrence S. Shepard 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 Lawrence S. Shepard 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) Lawrence S. Shepard an individual whose address is 110 N. Franklin St., 

Rm. 421, 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, Lawrence S. Shepard acting for his personal account 

at Imperial Securities, Inc., sold one contract of March pork bellies to Stuart 

N. Gimbel who was also acting for his own account at Imperial Securities, Inc. 

Such transaction between these two brokers who were both qualified to trade for 

the same clearing member was reported as being made with another floor broker. 

On February 14, 1969, Lawrence S. Shepard, acting for the account of a 

customer of Imperial Securities, Inc., sold four contracts of March pork bellies 

to Stuart N. Gimbel who was acting for his personal account at Imperial 

Securities, Inc. Such transaction between these two brokers who were both 

qualified to trade for the same clearing member was reported as being made with 

another floor broker. 

On February 17, 1969, Lawrence S. Shepard, acting for his personal account at 

Imperial Securities, Inc., bought three contracts of March pork bellies from 

Leonard B. Feldman who was also acting for his own account at Imperial 

Securities, Inc. Such transaction between these two brokers who were both 

qualified to trade for the same clearing member was made with the assistance of 
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another floor broker who entered into a wash and accommodation transaction with 

them. 

On February 17, 1969, Lawrence S. Sheapard acting for his personal account at 

Imperial Securities, Inc., sold two contracts of March pork 

bellies to Leonard B. Feldman who was also acting for his personal account at 

Imperial Securities, Inc. Such transaction between these two brokers who were 

qualified to trade for the same clearing member was reported as being made with 

another broker. 

On February 17, 1969, Lawrence S. Shepard, acting for the account of a 

customer of Imperial Securities, Inc., purchased one contract of March pork 

bellies from Leonard B. Feldman who was acting for his personal account at 

Imperial Securities, Inc. Such transaction between these two brokers who were 

qualified to trade for the same clearing member was reported as being made with 

another broker. 

On February 10, 1969, Lawrence S. Shepard, acting for the accounts of 

customers of Imperial Securities, Inc., purchased five contracts of March pork 

bellies from Michael F. Winner who was also acting for the account of a customer 

of Imperial Securities, Inc. Such transaction between these two brokers who 

were qualified to trade for the same clearing member was made with the 

assistance of another floor broker who entered into a wash and accommodation 

transaction with them. 

The Commodity Exchange Authority has advised Lawrence S. Shepard that his 

actions as described above, were in violation of section(s) 4c 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 Lawrence S. Shepard 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 

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 14 day of Dec 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

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