Page 1 

Commodity Futures Trading Commission 

CEA CASES 

NAME: RICHARD W. ROSE 

DOCKET NUMBER: STIPULATION 99 

DATE: MARCH 11, 1966 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Richard W. Rose 

Stipulation of Compliance Under the Commodity Exchange Act No. 99 

The Secretary of Agriculture has reason to believe that Richard W. Rose 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 Richard W. Rose 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 

Richard W. Rose stipulates the following facts are true: 

(1) Richard W. Rose, an individual whose address is c/o Rodman & Renshaw, 209 

South LaSalle Street, Chicago, Illinois 60604, is now and was at all times 

mentioned herein a member of the Board of Trade of the City of Chicago, 

hereinafter called the Chicago Board of Trade, a duly designated contract market 

under the Commodity Exchange Act. 

(2) The registration of Richard W. Rose as floor broker under the Commodity 

Exchange Act for the calendar year 1965 expired on December 31, 1965, and the 

said Richard W. Rose did not submit an application for registration as a floor 

broker under the act for the calendar year 1966 

until after the close of the trading session on the Chicago Board of Trade on 

January 6, 1966. 

(3) During the period from January 1 through January 6, 1966, Richard W. Rose 

acted as floor broker by executing for others orders for the purchase or sale of 

commodities for future delivery on or subject to the rules of the Chicago Board 

of Trade and for such services received and accepted compensation. 

(4) During the period from January 1 through January 6, 1966, the said 

Richard W. Rose executed 318 transactions in regulated commodity futures on the 

Chicago Board of Trade. However, with respect to 274 of such transactions, in 

each instance he failed to prepare a trading card or other record clearly 

identifying the opposite floor broker or other trader with whom such transaction 

was executed. 

The Secretary of Agriculture has advised Richard W. Rose that by reason of 

the acts set forth in paragraphs (2) and (3) above, he has violated section 4e 

of the act and section 1.8 of the regulations thereunder and that by reason of 

his failure to keep full and complete records of futures transactions, as 

described in paragraph (4) above, he has violated section 4g of the act and 

section 1.35 of the regulations thereunder. 

The said Richard W. Rose agrees to desist from such acts and practices in the 

future. He further understands and agrees that this stipulation shall be 
Page 2 

admissible as evidence of such acts and practices in any future proceeding based 

upon acts or practices in addition to 

those referred to herein 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 make stipulations of 

compliance a matter of public record. 

Done at Chicago, Illinois, this 

11th day of March 1966 

[SEE SIGNATURE IN ORIGINAL] 

Richard W. Rose 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
Page 3 
Page 4