Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: GROW INVESTMENTS, STUART N. GIMBEL, AND LAURENCE M. ROSENBERG 

DOCKET NUMBER: STIPULATION 137 

DATE: MAY 11, 1972 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Grow Investments, Stuart M. Gimbel, and Laurence N. Rosenberg 

Stipulation of Compliance Under the Commodity Exchange Act No. 137 

The Secretary of Agriculture has reason to believe that Grow Investments, 

Stuart M. Gimbel and Laurence M. Rosenberg have violated the provisions of the 

Commodity Exchange Act (7 U.S.C., Chapter 1) and the regulations of the 

Secretary of Agriculture promulgated thereunder. No complaint with respect to 

such violations has been issued and the said Grow Investments, Stuart N. Gimbel 

and Laurence M. Rosenberg are 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 

Grow Investments, Stuart N. Gimbel, and Laurence M. Rosenberg stipulate the 

following facts are true. 

(1) Grow Investments is now, and was at all times material herein, a 

registered futures commission merchant under the Commodity Exchange Act with an 

office and principal place of business at 110 North Franklin Street, Chicago, 

Illinois 60604. 

(2) Stuart N. Gimbel and Laurence M. Rosenberg, individuals whose business 

address is the same as that of Grow Investments, are now, and were at all times 

material herein, general partners of Grow Investments and responsible for its 

management, direction and control. 

(3) As of March 24, March 31 and May 4, 1971, Grow Investments was 

undersegregated in the amounts of $ 385.50, $ 253.50 and $ 3,447.50, 

respectively. That is, the total amount of customers' funds held in segregation 

in order to comply with the requirements of section 4d(2) of the Commodity 

Exchange Act was insufficient, by the above amounts, to pay all credits and 

equities to customers. 

(4) Grow Investments failed to compute and keep a record as of the close of 

the market on each of the four business days from January 18 through January 21, 

1972, shoving the amount of money, securities and property owing or accruing to 

its customers which it was required to have in segregated account for such 

customers in order to comply with the requirements of section 4d(2) of the 

Commodity Exchange Act. 

(5) Grow Investments failed to prepare and retain a written computation of 

its net worth for the months of January, February, March, April, July, August, 

November and December 1971. 

The Commodity Exchange Authority has advised Grow Investments, Stuart N. 

Gimbel and Laurence M. Rosenberg that the undersegregation described in 

paragraph (3) above, and the failure to compute and keep a record as described 

in paragraph (4) above, were in violation of section 4d(2) of the Commodity 

Exchange Act and section 1.32 of the regulations thereunder, and that the 
Page 2 

failure to prepare and retain a record as described in paragraph (5) above, was 

in violation of section 1.10(f) of the regulations under the said Act. 

The said Grow Investments, Stuart N. Gimbel and Laurence M. Rosenberg agree 

to desist from such acts and practices in the future. They further understand 

and agree that this stipulation is admissible as evidence of such acts and 

practices in any future proceeding based upon acts and practices in addition to 

those referred to herein which may be brought by the Secretary of Agriculture 

against any of them under the provisions of the said Act. Grow Investments, 

Stuart N. Gimbel and Laurence M. Rosenberg also understand 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 [ILLEGIBLE TEXT], this 

11 day of May 1972. 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Grow Investments By 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Stuart N. Gimbel 

[SEE SIGNATURE IN ORIGINAL] 

Laurence M. Rosenberg 

LOAD-DATE: June 16, 2008 
Page 3