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Commodity Futures Trading Commission 

CEA CASES 

NAME: RODMAN AND RENSHAW, AND FRANCIS J. COUGHLIN 

DOCKET NUMBER: STIPULATION 27 

DATE: SEPTEMBER 9, 1955 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Rodman (and) Renshaw, and Francis J. Coughlin 

Stipulation of Compliance under the Commodity Exchange Act No. 27 

WHEREAS, the Secretary of Agriculture has reason to believe that Rodman and 

Renshaw, a partnership, and Francis J. Coughlin have violated the Commodity 

Exchange Act (7 U.S.C. 1-17a) and the rules and regulations thereunder (17 CFR, 

Chapter 1) by virtue of certain transactions involving the purchase and sale of 

soybean futures, and 

WHEREAS, no complaint with respect to such violations has been issued, and 

WHEREAS, section O.4(a) of the rules of practice under the Commodity Exchange 

Act (17 CFR 0.4(a)) provides that at any time prior to the issuance of a 

complaint in any proceeding, the Secretary of Agriculture may, in his 

discretion, enter into a stipulation with a prospective respondent whereby the 

latter admits the material facts and agrees to discontinue the acts or practices 

which are intended to be set up as violative of the statute, and 

WHEREAS, the said Rodman and Renshaw, a partnership, and Francis J. Coughlin 

are desirous of disposing of this matter by entering into such a stipulation, 

NOW, THEREFORE, the said Rodman and Renshaw, a partnership, and Francis J. 

Coughlin hereby stipulate and represent that the following facts are true: 

1. Rodman and Renshaw is now and was at all times mentioned herein a 

partnership with an office and place of business at 209 South LaSalle Street, 

Chicago, Illinois. At all such times the said partnership was a registered 

futures commission merchant under the Commodity Exchange Act, and exercised 

membership trading privileges and clearing privileges on the Board of Trade of 

the City of Chicago, hereinafter called the Chicago Board of Trade, a duly 

designated contract market. 

2. Francis J. Coughlin, an individual whose address is 209 South LaSalle 

Street, Chicago, Illinois, is now and was at all times mentioned herein a 

partner in the said firm of Rodman and Renshaw, a registered floor broker under 

the Commodity Exchange Act, and a member of the Chicago Board of Trade. 

3. Section 1.38 of the rules and regulations under the Commodity Exchange Act 

(17 CFR, 1954 Supp., 1.38) provides as follows: 

All purchases and sales of any commodity for future delivery on or subject to 

the rules a of a contract market shall be executed openly and competitively as 

to price by open outcry or posting of bids and offers or by other equally open 

and competitive methods, in the trading pit or ring or similar place provided by 

the contract market, during the regular hours prescribed by the contract market 

for trading in such commodity: Provided, however, That 
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this requirement shall not apply to such transactions as are executed in 

accordance with written rules of the contract market which have been submitted 

to and not disapproved by the Secretary of Agriculture, specifically providing 

for the noncompetitive execution of such transactions. 

4. Regulation 1832A of the Chicago Board of Trade prohibits trading in 

soybean futures during the last seven days of a delivery month. Pursuant to the 

said regulation, trading in July 1955 soybean futures terminated at the close of 

business on July 20, 1955. 

5. On July 21, 1955, Rodman and Renshaw purchased 390,000 bushels of July 

1955 soybean futures by direct and private negotiation with the seller. The 

said transaction was consummated pursuant to arrangements made on behalf of the 

said Rodman and Renshaw by the said Francis J. Coughlin, who also acted as the 

broker for the seller. Such transaction was not within any of the exceptions 

specified in section 1.38 of the rules and regulations under the Commodity 

Exchange Act (17 CFR 1.38), and was in violation of the said section and Act. 

In addition to admitting the foregoing facts, the said Rodman and Renshaw and 

Francis J. Coughlin hereby agree to discontinue all such acts and practices and 

all other acts and practices which are in violation of the Commodity Exchange 

Act or the rules and regulations thereunder, and further specifically agree that 

this stipulation shall be admissible as evidence of acts and practices in 

violation of the Commodity Exchange 

Act and the rules and regulations thereunder in any subsequent proceeding 

brought against the said Rodman and Renshaw or Francis J. Coughlin, or either of 

them, under the provisions of the said Act. 

Done at Chicago, Illinois 

this 9th day of Sept., 1955 

/s/ Rodman & Renshaw 

Rodman and Renshaw 

by /s/ T. C. Rodman 

/s/ Francis J. Coughlin 

Francis J. Coughlin 

Witnessed by: 

/s/ Chas. Renshaw 

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