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Commodity Futures Trading Commission 

CEA CASES 

NAME: STUART N. GIMBEL 

DOCKET NUMBER: STIPULATION 118 

DATE: DECEMBER 14, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Stuart N. Gimbel 

Stipulation of Compliance Under the Commodity Exchange Act No. 118 

The Secretary of Agriculture has reason to believe that Stuart N. Gimbel 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 Stuart N. Gimbel 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 

Stuart N. Gimbel 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) Stuart N. Gimbel an individual whose address is 110 N. Franklin Street, 

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 11, 1969, Stuart N. Gimbel took the opposite side of 

customers' orders for the purchase of ten contracts of March pork bellies 

noncompetitively without obtaining the prior consent of such customers. The 

purchases were made by Stuart N. Gimbel for the accounts of customers of 

Imperial Securities, Inc. The opposite side of the transactions were made by 

Stuart N. Gimbel for his own account at Imperial Securities, Inc. In connection 

with these transactions Stuart N. Gimbel prepared records purporting to show 

that the opposite side of the transactions had been made with another floor 

broker. 

On February 17, 1969, Stuart N. Gimbel, acting for the accounts of customers 

of Imperial Securities, Inc., purchased six contracts of March pork bellies from 

Leonard B. Feldman who was acting for his own account at Imperial Securities, 

Inc. Such transactions between these two brokers who were both qualified to 

trade for the same clearing member were reported as being made with another 

floor broker. 
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On February 14, 1969, Stuart N. Gimbel acting for his personal account at 

Imperial Securities, Inc. purchased one contract of March pork bellies from 

Lawrence S. Shepard who was also acting for his personal account at Imperial 

Securities, Inc. Such transaction between these two brokers who were both 

qualified to trade for the same clearing member was reported as being made with 

another floor broker. 

On February 14, 1969, Stuart N. Gimbel acting for his personal account at 

Imperial Securities, Inc., purchased four contracts of March pork bellies from 

Lawrence S. Shepard who was acting for the account of a customer of Imperial 

Securities, Inc. Such transaction between these two brokers who were both 

qualified to trade for the same clearing member was reported as being made with 

another floor broker. 

The Commodity Exchange Authority has advised Stuart N. Gimbel 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 Stuart N. Gimbel 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 day of 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

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