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Commodity Futures Trading Commission 

CEA CASES 

NAME: BENEDICT K. GOODMAN 

DOCKET NUMBER: 81 

DATE: APRIL 14, 1958 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Benedict K. Goodman, Respondent 

CEA Docket No. 81 

Complaint and Notice of Hearing under Section 6(b) of the Commodity Exchange 

Act 

There is reason to believe that the respondent, Benedict K. Goodman, has 

violated the provisions of the Commodity Exchange Act (7 U.S.C. 1952 ed., 

Chapter 1), and the rules and regulations made pursuant to its requirements (17 

CFR, Part 1), and in accordance with the provisions of section 6(b) of the said 

act (7 U.S.C. 1952 ed., § 9), this complaint and notice of hearing is issued 

stating the charges in that respect as follows: 

I 

Respondent Benedict K. Goodman is an individual whose address is 636 Church 

Street, Evanston, Illinois. At all times material to this complaint he was a 

member of the Board of Trade of the City of Chicago. 

II 

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

From December 31, 1957, through February 21, 1958, the respondent held total 

speculative net long positions in the March 1958 rye future on the Chicago Board 

of Trade which ranged between 580,000 and 700,000 bushels, and total speculative 

net long positions in all rye futures combined on the Chicago Board of Trade 

which ranged between 730,000 and 1, 085, 000 bushels. By reason thereof, the 

respondent traded in rye for future delivery on a contract market in amounts 

which resulted in positions in excess of the maximum permissible quantity of 

500,000 bushels, in violation of section 4a of the Commodity Exchange Act (7 

U.S.C. 1952 ed., § 6a), and the order of the Commodity Exchange Commission 

establishing limits on positions and trading in rye for future delivery (17 CFR 

150.3). 

IV 

By reason of the fact that the positions in rye futures held by the 

respondent from December 31, 1957, through February 21, 1958, exceeded 200,000 

bushels in a single future, as described in paragraph III, the respondent was in 

reporting status and was required to report to the Commodity Exchange Authority 

with respect to all transactions executed and all positions held for his account 

in all rye futures on all boards of trade during such period, as provided in 

section 4i of the Commodity Exchange Act and sections 2.10, 2.11, 2.12, and 2.21 
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of the rules and regulations thereunder (7 U.S.C. 1952 ed., § 6i; 17 CFR 2.10, 

2.11, 2.12, 2.21). On January 22, 23, 24, 28, February 4, 5, 10, 12, 17 and 19, 

1958, the respondent bought or sold rye futures on the Chicago Board of Trade 

and failed or refused to report such purchases and sales and the resulting 

positions to the Commodity Exchange Authority, in violation of the aforesaid 

sections of the Commodity Exchange Act and the regulations. 

V 

During February 1956, the respondent held speculative positions in rye 

futures on the Chicago Board of Trade which exceeded the maximum permissible 

limit, and after notification by the Commodity Exchange Authority, brought 

himself into compliance by reducing such 

positions. At or about the same time, the Commodity Exchange Authority 

furnished the respondent with written information as to the requirements in this 

regard, and notified him that the holding of positions in rye futures in excess 

of 500,000 bushels constituted a violation of the Commodity Exchange Act. 

During the past twenty years, the respondent has been in reporting status and 

has filed reports with respect to his trading in rye futures on numerous 

occasions. The respondent was, therefore, aware of his obligations under the 

act and the regulations with respect to speculative limits and reporting 

requirements. In furtherance of and in an attempt to conceal his deliberate and 

willful violations of the act the respondent carried positions through various 

futures commission merchants but allowed no position through any one futures 

commission merchant to exceed 195, 000 bushels, just below the level of 200,000 

bushels at which the futures commission merchant would have been required to 

report to the Commodity Exchange Authority. 

Therefore, the said respondent, Benedict K. Goodman, is hereby notified to be 

and appear at a hearing to be held at 10:00 a.m. local time, on the 10th day of 

June, 1958, in Room 1200, Chicago Board of Trade Building, 141 West Jackson 

Boulevard, Chicago, Illinois, before a referee designated to conduct such 

hearing, and 

then and there show cause, if any there be, why an order should not be made 

directing that all contract markets refuse all trading privileges to the 

respondent for such period of time as may be determined. The respondent will 

have twenty (20) days after the receipt of this notice of hearing in which to 

file with the Hearing Clerk, United States Department of Agriculture, Washington 

25, D. C., an answer with an original and five copies, fully and completely 

stating the nature of the defense and admitting or denying, specifically and in 

detail, each material and relevant allegation of this complaint. Allegations 

not answered will be deemed admitted for the purpose of this proceeding. 

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. 

Done at Washington, D. C., this 

14th day of April, 1958. 

/s/ Don Paarlberg 

Don Paarlberg 

Assistant Secretary 

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