Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: WALTER E. CAHILL 

DOCKET NUMBER: STIPULATION 114 

DATE: DECEMBER 7, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Walter E. Cahill 

Stipulation of Compliance Under the Commodity Exchange Act No. 114 

The Secretary of Agriculture has reason to believe that Walter E. Cahill 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 Walter E. Cahill 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 

Walter E. Cahill 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) Walter E. Cahill an individual whose address is Rm. 2174, 141 W. Jackson 

Blvd., 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 12, 1969, Walter E. Cahill made an apparent February/March, 

spread transaction in pork belly futures with another floor broker. Fifteen 

February pork bellies were bought at 33.60 for the accounts of customers of 

Bache & Co. and fifteen March pork bellies were sold at the same price for the 

personal account of Walter E. Cahill at Henner Brothers. In making this 

apparent spread transaction, Walter E. Cahill indirectly took the opposite side 

of customers' orders calling for the purchase of fifteen contracts of the 

February future at the market. 

On February 14, 1969, Walter E. Cahill acting for the account of a customer 

of a Maduff & Sons, noncompetitively and without prior consent took the opposite 

side of an order for the purchase of two contracts of March pork bellies and 

allocated such contracts to the account of another floor broker. In connection 

with this transaction Walter E. Cahill prepared records purporting to show that 

the transaction was made with the other floor broker. 
Page 2 

The Commodity Exchange Authority has advised Walter E. Cahill that his 

actions as described above, were in violation of section(s) 4b 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 Walter E. Cahill 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 7th day of Dec. 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
Page 3