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Commodity Futures Trading Commission 

CEA CASES 

NAME: WILLARD E. PLATT, GEORGE F. FREY, JR., OLIVER M. HIBBERD, PATRICK M. SHEA, 

HENRY C. GATLIN, F & G COMMODITIES, AND RALPH N. PETERS & CO. 

CITATION: 24 Agric. Dec. 105 

DOCKET NUMBER: 112 

DATE: FEBRUARY 10, 1965 

DOCUMENT TYPE: DECISION AND ORDER 

(No. 9611) 

In re WILLARD E. PLATT, GEORGE F. FREY, JR., OLIVER M. HIBBERD, PATRICK M. SHEA, 

HENRY C. GATLIN, F & G COMMODITIES, AND RALPH N. PETERS & CO. CEA Docket No. 

112. Decided February 10, 1965. 

Records requirements -- Suspension or registration and denial of trading 

privileges in abeyance -- Consent -- Ralph N. Peters & Co.

The registration of Ralph N. Peters & Co. as a futures commission merchant is 

suspended for a period of 10 days and its trading privileges on the contract 

markets are denied for a like period for failing to keep full and complete 

records as required by the act, such sanctions to be held in abeyance. 

Mr. Earl L. Saunders for Commodity Exchange Authority. Winston, Strawn, Smith & 

Patterson, of Chicago, Ill., for respondent Ralph N. Peters & Co. 

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) by the Assistant Secretary of Agriculture. 

Respondent Ralph N. Peters & Co. is one of seven respondents in this 

proceeding. The complaint charges that the said respondent failed to keep full 

and complete records of futures transactions in wilful violation of section 4g 

of the Commodity Exchange Act 

(7 U.S.C. 6g) and section 1.35 of the regulations issued thereunder (17 CFR 

1.35). 

No hearing has been held with respect to any of the respondents. On January 

25, 1965, respondent Ralph N. Peters & Co. submitted for filing in the record, 

under section 0.4(b) of the Rules of Practice (17 CFR 0.4(b)), a stipulation in 

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

in the complaint, and consents to the entry of the order contained herein. 

FINDINGS OF FACT

1. 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. 

2. Respondent Ralph N. Peters & Co., a partnership with offices at Room 2065, 

208 South LaSalle Street, Chicago, Illinois, is now and was at all times 

material herein a clearing member of the Chicago Board of Trade and a registered 

futures commission merchant under the Commodity Exchange Act. 
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3. Respondent Willard E. Platt was at all times material herein a partner in 

respondent Ralph N. Peters & Co. 

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

or sale of May 1963 soybean meal futures on the Chicago Board of Trade. Such 

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

commerce in soybean meal or the products or by-products thereof, or (b) 

determining the price basis of transactions in interstate commerce in soybean 

meal, or (c) delivering soybean meal sold, shipped, or received in interstate 

commerce for the fulfillment of such futures contracts. 

5. On December 19, 1962, respondent Platt acting as floor broker for 

respondent Ralph N. Peters & Co. sold 10 contracts (1,000 tons) of May 1963 

soybean meal futures at $ 65.10 per ton to David B. Wrisley. Respondent Platt, 

acting with knowledge that Weinberg, Shanley & Wrisley was the opposite clearing 

member on the said sale to David B. Wrisley, intentionally altered 

the trading card which he turned in to respondent Ralph N. Peters & Co. relating 

to the said sale so as to indicate that respondent Platt had sold the 10 

contracts of May 1963 soybean meal futures to respondent F & G Commodities as 

the opposite clearing member. 

6. On December 19, 1962, respondent Platt acting as floor broker for 

respondent Ralph N. Peters & Co. purchased 23 contracts (2,300 tons) of May 1963 

soybean meal futures from the firm of Lawrence J. Ryan & Company as opposite 

clearing member. Respondent Platt prepared and turned in a trading card to 

respondent Ralph N. Peters & Co. relating to the said transaction which 

purported to show the purchase of the 23 contracts of May 1963 soybean meal 

futures to have been from F & G Commodities as opposite clearing member when he 

knew that such purchase was from the said Lawrence J. Ryan & Company as opposite 

clearing member. 

7. All records prepared and maintained by respondent Ralph N. Peters & Co. 

relating to the transactions set forth in paragraphs 5 and 6 above were based 

upon the trading cards turned in to respondent Ralph N. Peters & Co. by its 

partner, respondent Platt, and did not show the names of the true opposite 

clearing members. 

CONCLUSIONS

Section 4g of the Commodity Exchange Act authorizes the Secretary of 

Agriculture to prescribe the form and manner in which a registered futures 

commission merchant shall keep books and records, and authorizes the Secretary 

to revoke or suspend a futures commission merchant's registration for failure or 

refusal to comply. Section 1.35 of the regulations set forth certain 

information which each clearing member of a contract market must include in his 

records. Among the items of information which must be shown by the records of a 

clearing member is the identity of the clearing member on the opposite side of 

each transaction. The facts described in Findings of Fact 5 through 7 hereof 

demonstrate that the books and records of respondent Ralph N. Peters & Co., a 

registered futures commission merchant and a clearing member of the Chicago 

Board of Trade, did not contain the names of the true opposite clearing members 

in the 

transactions in question, and that the omission of this information was 

knowingly caused by respondent Willard E. Platt, a partner in respondent Ralph 

N. Peters & Co. It is concluded, therefore, that respondent Ralph N. Peters & 

Co. violated section 4g of the act and section 1.35 of the regulations as 

charged in the complaint. 

The complainant states that the administrative officials of the Commodity 

Exchange Authority have carefully considered the proposed stipulation and the 
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terms of the order to which respondent Ralph N. Peters & Co. proposes to 

consent. It is the opinion of the administrative officials that in the 

circumstances the proposed sanction would be adequate, and that the prompt entry 

of such an order would constitute a satisfactory disposition of this case 

against the said respondent, serve the public interest, and effectuate the 

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

that the stipulation and waiver be accepted and that the proposed order be 

issued. It is so concluded. 

ORDER

The registration of respondent Ralph N. Peters & Co. as a futures commission 

merchant under the Commodity Exchange Act is hereby suspended for a period of 

ten days, and all contract markets are hereby directed to refuse all trading 

privileges to the said Ralph N. Peters & Co. for the said period of ten days, 

provided, however, that the aforesaid suspension of registration and refusal of 

trading privileges shall not become effective unless, after complaint and 

hearing in accordance with established procedure, respondent Ralph N. Peters & 

Co. should be found to have violated the Commodity Exchange Act within one year 

from the date of entry of this order, in which event the Secretary of 

Agriculture may, without further notice to respondent Ralph N. Peters & Co., 

issue a supplemental order making effective forthwith the aforesaid suspension 

of registration and refusal of trading privileges. 

A copy of this Decision and Order shall be served on each of the respondents 

and on each contract market. 

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