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Commodity Futures Trading Commission 

CEA CASES 

NAME: RICHARD J. SENNOTT AND AUGUST COMENZO 

DOCKET NUMBER: 133 

DATE: NOVEMBER 22, 1965 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Richard J. Sennott and August Comenzo, Respondents 

CEA Docket No. 133 

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

Act 

There is reason to believe that the respondents, Richard J. Sennott and 

August Comenzo, have violated the Commodity Exchange Act (7 U.S.C. 1 et seq.) 

and the regulations made pursuant thereto (17 CFR, Part 1), and in accordance 

with the provisions of section 6(b) of the said act (7 U.S.C. 9), this complaint 

and notice of hearing is issued stating the charges in that respect as follows: 

I 

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. At all times material herein, 

respondent Sennott was authorized to trade on a discretionary basis in commodity 

futures for the "scalp" account of Honeymead Trading Corporation, a clearing 

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

II 

Respondent August Comenzo, an individual whose address is 190 Washington 

Street, Hempstead, New York, is now and was at all times material herein a 

registered floor broker under the Commodity Exchange Act. He was at all times 

material herein a member of the Board of Trade of the City of Chicago. 

III 

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. 

IV 

The transactions referred to in this complaint 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. 
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V 

In each of the transactions listed below, respondent Richard J. Sennott, 

acting as floor broker, filled a purchase order for his principal, a clearing 

member of the Chicago Board of Trade, by entering into a noncompetitive trade 

with respondent August Comenzo. In each of such transactions, respondent 

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

respondent Sennott and pursuant to an arrangement or understanding existing 

between him and respondent Sennott, took the sale side of such transaction for 

the "scalp" account of Honeymead Trading Corporation at the price bid by 

respondent Sennott. 

Respondent

Sennott's 

Date Commodity Future Quantity Price Principal 

1963 (No. of (Meal-Dollars (Oil-Cents Contracts) per Ton) per Pound) Sept. 25 Soybean Meal May 1964 11 74.00 Stratton 

Grain Co. 

 

Oct. 17 Soybean Oil May 1964 5 9.45 Ferguson 

Grain Co. 

 Nov. 5 Soybean 

Oil Dec. 1963 5 9.65 Stratton 

Grain Co. Nov. 6 Soybean 

Meal May 1964 7 75.25 Ferguson 

Grain Co. 

 Nov. 8 Soybean Oil Jan. 1964 9 10.32 Ferguson 

Grain Co. 

 Dec. 19 Soybean 

Oil Oct. 1964 2 9.53 Ferguson 

Grain Co. Dec. 31 Soybean 

Meal Mar. 1964 15 76.30 Ferguson 

Grain Co. 

 

1964 Jan. 2 Soybean 

Oil Jan. 1964 10 8.00 Ferguson 

Grain Co. 

Jan. 2 Soybean 

Oil Jan. 1964 15 8.02 Ferguson 

Grain Co. 

 

VI 

In each of the transactions listed below, respondent Richard J. Sennott, 

acting as floor broker, filled a sell order for his principal, a clearing member 

of the Chicago Board of Trade, by entering into a noncompetitive trade with 

respondent August Comenzo. In each of such transactions, respondent Comenzo, 

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

Sennott and pursuant to an arrangement or understanding existing between him and 

respondent Sennott, took the purchase side of such transaction for the "scalp" 
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account of Honeymead Trading Corporation at the price offered by respondent 

Sennott. 

Respondent

Sennott's 

Date Commodity Future Quantity Price Principal 

1963 (No. of (Meal-Dollars (Oil-Cents Contracts) per Ton) per Pound) 

Oct. 9 Soybean Oil Jan. 1964 23 9.80 Ferguson 

Grain Co. 

Oct. 31 Soybean Meal Dec. 1963 7 73.40 Stratton 

Grain Co. 

Nov. 6 Soybean Meal Jan. 1964 6 74.30 Ferguson 

Grain Co. 

Nov. 21 Soybean Oil Jan. 1964 25 7.96 Ferguson 

Grain Co. 

Dec. 2 Soybean Meal Dec. 1963 5 72.45 Stratton 

Grain Co. 

 Dec. 23 Soybean Oil May 1964 10 8.68 Ferguson 

Grain Co. 

 

Dec. 31 Soybean Meal July 1964 15 77.70 Ferguson 

Grain Co. 

 

VII 

On January 13, 1964, respondent Richard J. Sennott, acting for his own 

account, purchased 1900 tons of March 1964 soybean meal futures at a price of $ 

74.55 per ton by entering into a noncompetitive trade with respondent August 

Comenzo, and on February 27, 1964, respondent Sennott, acting for his own 

account, purchased 1600 tons of May 1964 soybean meal futures at a price of $ 

70.05 per ton by entering into a noncompetitive trade with respondent Comenzo. 

In each of such transactions, respondent Comenzo, acting as floor broker 

pursuant to an order which he received from respondent Sennott and pursuant to 

an arrangement or understanding existing between him and respondent Sennott, 

took the sale side of such transaction for the "scalp" account of Honeymead 

Trading Corporation at the price bid by respondent Sennott. 

VIII 

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. In each of such transactions, respondent Sennott 

filled an order for a selling customer and filled an order for a buying 

customer. 

See original document-page 5 

Quantity Price 

Date Commodity Future Purchased and Sold (Meal-Dollars (Oil-Cents

1963 (No. of 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
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 Quantity Price 

Date Commodity Future Purchased and Sold (Meal-Dollars (Oil-Cents

1963 (No. of Contracts) per Ton) per Pound)

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 

April 28 Soybean Oil May 1964 1 7.80

April 29 Soybean Oil May 1964 4 7.88

April 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 

IX 

By reason of the acts described in paragraphs V and VI, respondent Sennott 

filled orders of his customers by offset in wilful violation of section 4b(D) of 

the Commodity Exchange Act (7 U.S.C. 6b(D)). By reason of the acts described in 

paragraphs V, VI and VII, respondents Sennott and Comenzo executed purchases and 

sales of commodities for future delivery in a manner which was not open and 

competitive, as required by section 1.38 of the regulations (17 CFR 1.38), and 

in wilful violation thereof. By reason of the acts described in paragraph VIII, 

respondent Comenzo entered into transactions which were, or were of the 

character of, "wash sales" and "accommodation trades" in wilful violation of 

section 4c(A) of the Commodity Exchange Act (7 U.S.C. 6c(A)). 

WHEREFORE, it is hereby ordered that this complaint and notice of hearing be 

served upon the said respondents. The respondents will have twenty (20) days 

after the receipt of this complaint in which to file with the Hearing Clerk, 

United States Department of Agriculture, Washington, D. C., 20250, 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. Failure to file an answer will 

constitute an admission of all the material allegations of this complaint and a 

waiver of hearing. The respondents are hereby notified 

that unless hearing is waived, either expressly or by failure to file an answer 

and request a hearing, a hearing will be held at 10:00 a.m., local time, on the 

26th day of January 1966, in Chicago, Illinois, at a place therein to be 

specified later, before a referee designated to conduct such hearing. At such 

hearing the respondents will have the right to appear and show cause, if any 

there be, why an order should not be made suspending or revoking the 

registrations of the respondents as floor brokers, and directing that all 

contract markets refuse all trading privileges to each respondent for such 

period of time as may be determined. 

It is ordered that this complaint and notice of hearing be served on each of 

the said respondents at least twenty (20) days prior to the date set for 

hearing. 

Done at Washington, D. C., on 

November 22, 1965 

[SEE SIGNATURE IN ORIGINAL] 
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Assistant Secretary 

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