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Commodity Futures Trading Commission 

CEA CASES 

NAME: RICHARD J. SENNOTT, AND AUGUST COMENZO 

CITATION: 25 Agric. Dec. 297 

DOCKET NUMBER: 133 

DATE: MARCH 2, 1966 

DOCUMENT TYPE: DECISION AND ORDER 

(No. 10,430) 

In re RICHARD J. SENNOTT, AND AUGUST COMENZO. CEA Docket No. 133. Decided 

March 2, 1966. 

Stipulation as to August Comenzo -- Noncompetitive and accommodation trades -

- Wash sales -- Denial of trading privileges

Trading privileges of respondent August Comenzo on the contract markets are 

denied to him for a period of 15 days for activities involving noncompetitive 

and accommodation trades and wash sales. If he were registered as a floor 

broker under the act at the present time, the order herein would also include a 

suspension of his registration for a like period. 

Mr. Earl L. Saunders for Commodity Exchange Authority. 

Mr. Sidney G. Hamper, of Chicago, Ill., for respondent August Comenzo. 

Decision by Thomas J. Flavin, Judicial Officer

PRELIMINARY STATEMENT

This is an administrative proceeding under the Commodity Exchange Act (7 

U.S.C. 1 et seq.), instituted by a complaint and notice of hearing issued under 

section 6(b) of the act (7 U.S.C. 9) on November 23, 1965, by the Assistant 

Secretary of Agriculture. 

The complaint names as respondents two individuals, Richard J. Sennott and 

August Comenzo. At the time of the violations charged 

in the complaint, both respondents were registered floor brokers under the 

Commodity Exchange Act. At the present time respondent Comenzo is not 

registered under the act. The proceeding is concerned with transactions in 

soybean oil or soybean meal futures on the Chicago Board of Trade during the 

period July 11, 1963, through October 27, 1964. Respondent Comenzo is charged 

with making accommodation trades and wash sales and entering into noncompetitive 

trades, in willful violation of section 4c of the Commodity Exchange Act (7 

U.S.C. 6c) and section 1.38 of the regulations issued under the act (17 CFR 

1.38). 

No hearing has been held with respect to either respondent. On January 26, 

1966, a consent order was issued against respondent Sennott, concluding the 

proceeding as against him. On February 8, 1966, respondent Comenzo submitted a 

stipulation under section 0.4(b) of the rules of practice (17 CFR 0.4(b)), in 

which he admits the facts hereinafter set forth, waives hearing on the charges, 

and consents to the entry of an order (1) directing the denial of all trading 

privileges to him on all contract markets for a period of 15 days, and (2) 

suspending him as a registrant under the Commodity Exchange Act for a period of 

15 days. 
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FINDINGS OF FACT

1. Respondent Richard J. Sennott, an individual whose address is 141 West 

Jackson Boulevard, Chicago, Illinois, is now and was at all times material 

herein a member of the Board of Trade of the City of Chicago and a registered 

floor broker under the Commodity Exchange Act. 

2. Respondent August Comenzo, an individual whose address is 190 Washington 

Street, Hempstead, New York, was at all times material herein a registered floor 

broker under the Commodity Exchange Act and a member of the Board of Trade of 

the City of Chicago. 

3. 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. 

4. The transactions referred to herein relate to contracts for the purchase 

or sale of soybean oil or soybean meal futures on the Chicago Board of Trade. 

Such contracts could have been used for (a) hedging transactions in interstate 

commerce in soybean oil or soybean meal or the products or byproducts thereof, 

or (b) determining 

the price basis of transactions in interstate commerce in soybean oil or soybean 

meal, or (c) delivering soybean oil or soybean meal sold, shipped, or received 

in interstate commerce for the fulfillment of such futures contracts. A soybean 

oil futures contract on the Chicago Board of Trade calls for the delivery of 

60,000 pounds of soybean oil and a soybean meal futures contract on the Chicago 

Board of Trade calls for the delivery of 100 tons of soybean meal. 

5. In each of the transactions listed below, respondent August Comenzo 

entered into a trade with respondent Richard J. Sennott whereby respondent 

Comenzo, acting as floor broker pursuant to an order which he received from 

respondent Sennott, took the sale side of such trade for the trading account of 

Honeymead Trading Corporation at the price bid by respondent Sennott. 

Date Commodity Future Quantity Price 1963 (No. of (Meal -- Dollar (Oil -- Cents

Contracts) per Ton) per Pound) 

Sept. 25 Soybean Meal May 1964 11 74.00 

Oct. 17 Soybean Oil May 1964 5 9.45

Nov. 5 Soybean Oil Dec. 1963 5 9.65

Nov. 6 Soybean Meal May 1964 7 75.25 Nov. 8 Soybean Oil Jan. 1964 9 10.32

Dec. 19 Soybean Oil Oct. 1964 2 9.53

Dec. 31 Soybean Meal Mar. 1964 15 76.30 

1964 

Jan. 2 Soybean Oil Jan. 1964 10 8.00

Jan. 2 Soybean Oil Jan. 1964 15 8.02

6. In each of the transactions listed below, respondent August Comenzo 

entered into a trade with respondent Richard J. Sennott whereby respondent 

Comenzo, acting as floor broker pursuant to an order which he received from 

respondent Sennott, took the purchase side of such trade for the trading account 

of Honeymead Trading Corporation at the price offered by respondent Sennott. 

Date Commodity Future Quantity Price 

1963 (No. of (Meal -- Dollar (Oil -- Cents 

Contracts) per Ton) per Pound) 

Oct. 9 Soybean Oil Jan. 1964 23 9.80

Oct. 31 Soybean Meal Dec. 1963 7 73.40 Nov. 6 Soybean Meal Jan. 1964 6 74.30 

Nov. 21 Soybean Oil Jan. 1964 25 7.96

Dec. 2 Soybean Meal Dec. 1963 5 72.45 Dec. 23 Soybean Oil May 1964 10 8.68
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Date Commodity Future Quantity Price 

1963 (No. of (Meal -- Dollar (Oil -- Cents 

 Contracts) per Ton) per Pound) 

Dec. 31 Soybean Meal July 1964 15 77.70 

7. On January 13, 1964, respondent August Comenzo sold 1,900 tons of March 

1964 soybean meal futures at a price of $ 74.55 per ton by entering into a trade 

with respondent Richard J. Sennott, and on February 27, 1964, respondent Comenzo 

sold 1,600 tons of May 1964 soybean meal futures at a price of $ 70.05 per ton 

by entering into a trade with respondent Sennott. In each of such transactions, 

respondent Comenzo, acting as floor broker pursuant to an order which he 

received from respondent Sennott, took the sale side of such transaction for the 

trading account of Honeymead Trading Corporation at the price bid by respondent 

Sennott. 

8. In each of the transactions listed below, respondent August Comenzo, 

acting for his own account, simultaneously purchased from and sold to respondent 

Richard J. Sennott as the opposite floor broker the same quantity of the same 

future at the same price. 

Date Commodity Future Quantity Price 

1963 

(No. of (Meal -- Dollar (Oil -- Cents

Contracts) per Ton) per Pound) 

July 11 Soybean Meal Oct. 1963 9 68.90 

July 12 Soybean Meal Dec. 1963 6 68.25 July 15 Soybean Meal Oct. 1963 5 66.00 July 16 Soybean Meal Aug. 1963 3 67.35 

Aug. 27 Soybean Meal May 1964 7 68.50 Sept. 12 Soybean Meal Oct. 1963 3 69.65 

Sept. 16 Soybean Meal Dec. 1963 6 70.75 

Sept. 18 Soybean Oil Jan. 1964 5 8.80

Oct. 23 Soybean Oil May 1964 5 9.42

Oct. 31 Soybean Oil Mar. 1964 16 10.00

Nov. 1 Soybean Meal May 1964 25 75.15 Nov. 13 Soybean Meal Dec. 1963 9 73.70 1964 

Mar. 10 Soybean Oil Mar. 1964 10 7.69

Mar. 18 Soybean Meal May 1964 5 68.25 

Mar. 19 Soybean Meal May 1964 5 67.40 

April 6 Soybean Meal July 1964 10 66.35 Apr. 28 Soybean Oil May 1964 1 7.80

Apr. 29 Soybean Oil May 1964 4 7.88

Apr. 30 Soybean Oil Oct. 1964 10 8.35

May 20 Soybean Oil Oct. 1964 5 8.58

Aug. 3 Soybean Meal Jan. 1965 5 60.40 

Oct. 27 Soybean Oil May 1965 2 10.41

9. Each of the transactions, described in paragraphs five through eight 

above, was executed in a manner which was not open and competitive. In each of 

the transactions, described in paragraph 

eight above, respondent Comenzo made a wash trade for the purpose of 

accommodating respondent Sennott. 

CONCLUSIONS

The facts admitted by respondent Comenzo have been adopted as the findings 

herein. By reason of these findings, it is concluded that, as charged in the 

complaint, respondent Comenzo made accommodation trades and wash sales, and 

entered into noncompetitive trades, in willful violation of section 4c of the 

Commodity Exchange Act (7 U.S.C. 6c) and section 1.38 of the regulations (17 CFR 
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1.38). The complainant states that the administrative officials of the 

Commodity Exchange Authority have carefully considered the stipulation and 

waiver submitted by respondent Comenzo. The administrative officials believe 

that, if the decision makes it clear that the registration of respondent Comenzo 

as a floor broker under the Commodity Exchange Act would be suspended if he were 

now so registered, the prompt entry of an order providing for the proposed 

denial of trading privileges to respondent Comenzo would constitute a 

satisfactory disposition of the case as against him, and effectuate the purposes 

of the Commodity Exchange Act. The complainant recommends, therefore, that the 

stipulation and waiver be accepted and such a decision and order be issued. 

It is concluded that the complainant's recommendation should be adopted. If 

respondent Comenzo were registered as a floor broker under the Commodity 

Exchange Act at the present time, the order contained herein would include a 

suspension of such registration for a period of fifteen (15) days. However, 

since respondent Comenzo is not currently so registered, no such suspension is 

included in the order. 

ORDER

Effective April 4, 1966, all contract markets shall refuse all trading 

privileges to respondent August Comenzo for a period of 15 days, such refusal to 

apply to all trading done and all positions held by the said August Comenzo, 

directly or indirectly, whether for his own account or for any other account, 

directly or indirectly controlled by him. 

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