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Commodity Futures Trading Commission 

CEA CASES 

NAME: A. L. STAMM & CO. AND EVERARD M. C. STAMM 

DOCKET NUMBER: STIPULATION 98 

DATE: NOVEMBER 5, 1965 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: A. L. Stamm & Co. and Everard M. C. Stamm 

Stipulation of Compliance under the Commodity Exchange Act No. 98 

The Secretary of Agriculture has reason to believe that A. L. Stamm & Co. and 

Everard M. C. Stamm 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 (17 CFR, Chapter 1). No complaint with respect to such 

violations has been issued and A. L. Stamm & Co. and Everard M. C. Stamm 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, A. L. Stamm & Co. and Everard M. C. 

Stamm stipulate the following facts are true: 

(1) A. L. Stamm & Co. is and was at all times mentioned herein a partnership 

and a registered futures commission merchant under the Commodity Exchange Act 

with an office and principal place of business at 120 Broadway, New York, New 

York 10005. 

(2) Everard M. C. Stamm is and was at all times mentioned herein managing 

partner of A. L. Stamm & Co. 

(3) The acts and practices on the part of A. L. Stamm & Co. hereinafter 

described were directed and carried out under the supervision and control of 

Everard M. C. Stamm in his capacity as managing partner of A. L. Stamm & Co. 

(4) As of October 8, 1965, A. L. Stamm & Co. had failed to compute and keep a 

record as of the close of the market on each business day from October 1 through 

October 7, 1965, inclusive, showing the amount of money, security 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. Previous failures to compute and keep such 

records were discussed with Everard M. C. Stamm and other representatives of A. 

L. Stamm & Co. by Commodity Exchange Authority accountants at various times and 

were called to the attention of Everard M. C. Stamm and A. L. Stamm & Co. by the 

Director, Accounting and Licensing Division, Commodity Exchange Authority, in a 

letter dated May 10, 1965. 

The Secretary of Agriculture has advised A. L. Stamm & Co. and Everard M. C. 

Stamm that failure to compute and keep a record as described in paragraph (4) 

above was in violation of section 4d(2) of the Commodity Exchange Act and 

section 1.32 of the regulations thereunder. 

The said A. L. Stamm & Co. and Everard M. C. Stamm agree to desist from such 

acts and practices in the future. They further understand and agree that this 

stipulation shall be admissible as evidence of such acts and practices in any 

future proceeding based upon acts or practices in addition to those referred to 

herein which 
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may be brought against them by the Secretary of Agriculture under the provisions 

of the said act. They also understand that it is the practice of the Commodity 

Exchange Authority to make stipulations of compliance a matter of public record. 

Done at New York, New York, this 

5th day of November, 1965 

A. L. STAMM & CO. 

By [SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

Everard M. C. Stamm 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

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