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Commodity Futures Trading Commission 

CEA CASES 

NAME: CHARLES E. RITTEN, J. PETER RITTEN, AND LOUIS N. RITTEN & CO. 

DOCKET NUMBER: 118 

DATE: MARCH 26, 1964 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Charles E. Ritten, J. Peter Ritten, and Louis N. Ritten & Co., 

Respondents 

CEA Docket No. 118 

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

Act 

There is reason to believe that the respondents named herein 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 Act (7 U.S.C. § 9), this complaint and notice of hearing is 

issued stating the charges in that respect as follows: 

I 

The Minneapolis Grain Exchange, hereinafter called the exchange, is now and 

was at all times material herein a duly designated contract market under the 

Commodity Exchange Act. 

II 

Respondent Charles E. Ritten, an individual, whose business address is 109 

Grain Exchange Building, Minneapolis, Minnesota, is now and was at all times 

material herein a registered floor broker under the Commodity Exchange Act, a 

member of the exchange, and president of respondent Louis N. Ritten & Co. 

III 

Respondent J. Peter Ritten, an individual, whose business address is 109 

Grain Exchange Building, Minneapolis, Minnesota, is now and was at all times 

material herein a registered floor broker under the Commodity Exchange Act, a 

member of the exchange, and vice-president of respondent Louis N. Ritten & Co. 

IV 

Respondent Louis N. Ritten & Co., a corporation organized under the laws of 

the State of Minnesota with its principal office and place of business at 109 

Grain Exchange Building, Minneapolis, Minnesota, is now and was at all times 

material herein a registered futures commission merchant under the Commodity 

Exchange Act, and a clearing member of the exchange. 

V 

The transactions referred to in this complaint relate to contracts for the 

purchase or sale of grain futures on the exchange. Such contracts could have 

been used for hedging transactions in interstate commerce in such grains or the 

products or byproducts thereof, or for determining the price basis of 

transactions in interstate commerce in such commodities, or for delivering such 

commodities sold, shipped, or received in interstate commerce. 
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VI 

On the dates hereinafter listed, respondent Charles E. Ritten prepared, and 

turned in to respondent Louis N. Ritten & Co. and to F. H. Peavey & Company, 

another clearing member of the exchange, trading cards which purported to show 

that respondent Charles E. Ritten had executed the following transactions in the 

May 1963 wheat future on the exchange, when, in truth and in fact, no such 

transactions actually had taken place, but, rather, respondent Charles E. Ritten 

merely "carded" such transactions. Such "carding" resulted in respondent Louis 

N. Ritten & Co. taking the opposite side of its customers' orders. 

Purported Transactions 

for Customers of Date Louis N. Ritten & Co. Opposite Side 

1962 

Quantity Sold Price Clearing (Thousands of (Cents per Member Customer 

bushels) bushel) 

October 23 5 235- 1/2 F.H. Peavey Louis N. Ritten 

 & Company & Co. 

 

November 2 2 234- 1/8 F.H. Peavey Louis N. Ritten 

 & Company & Co. 

 

November 21 10 233- 3/4 F.H. Peavey Louis N. Ritten 

 & Company & Co. 

VII 

On the dates hereinafter listed, respondent Charles E. Ritten prepared, and 

turned in to respondent Louis N. Ritten & Co. and to the said F. H. Peavey & 

Company, trading cards which purported to show that 

respondent Charles E. Ritten had executed the following transactions in wheat 

futures on the exchange, when, in truth and in fact, no such transactions 

actually had taken place, but, rather, respondent Charles E. Ritten merely 

"carded" such transactions for the purpose of enabling respondent Louis N. 

Ritten & Co. to give reciprocal business to the said F. H. Peavey & 

Company.>100> >101> 

Date Future Quantity Price Buying 

1962 (Thousands (Cents per of bushels) bushel) Clearing Member Customer 

Oct. 29 May 1963 20 232-7/8 Louis N. C.E.Ritten 

Ritten & Co. 

 Oct. 29 Dec. 1962 10 232-1/2 Louis N. C.E.Ritten 

Ritten & Co. 

 Nov. 15 May 1963 10 233-7/8 F.H.Peavey Louis N. 

& Company Ritten & Co. 

 Nov. 16 May 1963 20 234-7/8 F.H.Peavey Louis N. 

& Company Ritten & Co. Nov. 21 Dec.1962 10 234-3/4 Louis N. C.E.Ritten 

Ritten & Co. 

Date Future Selling 

1962 

Clearing 

Member Customer 

Oct. 29 May 1963 F.H.Peavey Louis N. 

& Company Ritten & Co. 
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Date Future Quantity Price Buying 

1962 (Thousands (Cents per of bushels) bushel) Clearing 

 Member Customer 

Oct. 29 Dec. 1962 F.H.Peavey Louis N. 

& Company Ritten & Co. 

 Nov. 15 May 1963 Louis N. C.E. Ritten 

 Ritten 

 & Co. 

 Nov. 16 May 1963 Louis N. C.E. Ritten 

 Ritten 

 & Co. 

Nov. 21 Dec.1962 F.H.Peavey Louis N. 

& Company Ritten & Co. 

VIII 

On November 30, 1962, respondent J. Peter Ritten prepared, and turned in to 

respondent Louis N. Ritten & Co. and to the said F. H. Peavey & Company, trading 

cards which purported to show that respondent J. Peter Ritten had entered into a 

transaction on the exchange wherein he purchased for a customer of respondent 

Louis N. Ritten & Co., and sold for the account of respondent Louis N. Ritten & 

Co. at F. H. Peavey & Company, 4,000 bushels of May 1963 flaxseed futures at a 

price of $ 3.09 per bushel, when, in truth and in fact, no such transaction 

actually had taken place, but, rather, respondent J. Peter Ritten merely 

"carded" such transaction. Such "carding" resulted in respondent Louis N. 

Ritten & Co. taking the opposite side of its customers' order. 

IX 

On the dates hereinafter listed, respondents Charles E. Ritten and J. Peter 

Ritten entered into transactions in wheat futures with each other on the 

exchange, and in each such transaction, as shown in the tabulation below, one of 

the individual respondents purported to act for the account of respondent Louis 

N. Ritten & Co. at the said F. H. Peavey & Company, while the other individual 

respondent purported to act for the account of one of the individual respondents 

at respondent Louis N. Ritten & Co., when, in truth and in fact, both individual 

respondents were acting for the account of respondent Louis N. Ritten & Co. for 

the purpose of enabling it to give reciprocal business to the said F. H. Peavey 

& Company. 

Trades Made by Individual Respondents for the Account 

of Louis N. Ritten & Co. at Opposite Side of 

F. H. Peavey & Company Trade 

Floor Floor Purported 

Date Future Quantity Price Broker Broker Account 

1962 (Thousands (Cents per 

of bushels) bushel) Bought Sold Oct. 4 May 1963 5 233-3/4 C.E. Ritten J.P. Ritten J.P. Ritten

Oct. 9 Dec.1962 5 231 " " " " " " 

Oct. 12 May 1963 10 232-1/2 " " " " " " 

Nov. 7 May 1963 10 234-1/4 " " " " " " 

Nov. 12 Dec.1962 5 235-1/4 " " " " " " 

Nov. 12 May 1963 5 233-7/8 " " " " " " 

Nov. 13 May 1963 5 234-1/4 " " " " " " 

Nov. 13 Dec.1962 5 235-7/8 " " " " " " 
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Trades Made by Individual 

 Respondents for the Account of Louis N. Ritten & Co. at Opposite Side of F. H. Peavey & Company Trade 

 Floor Floor Purported 

Date Future Quantity Price Broker Broker Account 

1962 (Thousands (Cents per 

 of bushels) bushel) Bought Sold 

Nov. 13 Dec.1962 5 235-3/4 " " " " " " 

Nov. 16 Dec.1962 2 236-1/2 " " " " " " 

Nov. 16 May 1963 10 235 " " " " " " 

Nov. 20 Dec.1962 20 236-1/2 J.P. Ritten C.E. Ritten C.E. Ritten

Nov. 20 Dec.1962 30 236-5/8 C.E. Ritten J.P. Ritten J.P. Ritten

Nov. 21 Dec.1962 5 234-3/8 " " " " " " 

Nov. 30 May 1963 5 234-1/2 " " " " " " 

Dec. 5 May 1963 5 234-7/8 " " " " " " 

Dec. 6 May 1963 5 235-1/4 J.P. Ritten C.E. Ritten C.E. Ritten

Dec. 7 May 1963 5 234-3/4 C.E. Ritten J.P. Ritten J.P. Ritten

Dec. 17 May 1963 10 234-1/2 " " " " " " 

Dec. 19 May 1963 5 233-1/8 " " " " " " 

Dec. 20 May 1963 4 232-3/4 " " " " " " 

X 

On October 11, 1963, respondent Charles E. Ritten, acting for the account of 

respondent Louis N. Ritten & Co. at the clearing firm of Atwood-Larson Company, 

purchased and sold on the exchange in transactions with different floor brokers, 

15,000 bushels of December 1963 wheat futures at a price of $ 2.27-7/8 per 

bushel. Such transactions were entered into by respondent Charles E. Ritten for 

the account of respondent Louis N. Ritten & Co. for the sole purpose of giving 

reciprocal business to the said Atwood-Larson Company. 

XI 

On October 8, 1963, respondent J. Peter Ritten, acting for the account of 

respondent Louis N. Ritten & Co. at the clearing firm of Benson-Quinn Company, 

noncompetitively sold on the exchange 10,000 bushels of December 1963 wheat 

futures at a price of $ 2.30- 3/4 per bushel to respondent Charles E. Ritten, 

who was acting for a customer of respondent Louis N. Ritten & Co. To offset 

such sale, respondent J. Peter Ritten, on October 8, 1963, prepared, and turned 

in to the said Benson-Quinn Company, a trading card which purported to show a 

purchase of 10,000 bushels of December 1963 wheat futures for the account of 

respondent Louis N. Ritten & Co. at a price of $ 2.31 per bushel from respondent 

Louis N. Ritten & Co., as opposite clearing member, and respondent Charles E. 

Ritten, on the same date, prepared 

a trading card for respondent Louis N. Ritten & Co. which purported to show that 

he, acting for the account of one Wallace Arnt, had entered into such a 

transaction with the said Benson-Quinn Company, as the opposite clearing member, 

when, in truth and in fact, no such trade actually had taken place. 

XII 

By reason of the acts described in this complaint, the respondents bucketed 

customers' orders, in wilfull violation of section 4b of the Commodity Exchange 

Act (7 U.S.C. § 6b); offered to enter into and entered into transactions which 

constituted or were of the character of wash sales or fictitious sales, in 

wilfull violation of section 4c of the Commodity Exchange Act (7 U.S.C. § 6c); 

and failed to execute futures trades openly and competitively by open outcry in 

the trading pit of the exchange, in wilfull violation of section 1.38 of the 

regulations under the Commodity Exchange Act (17 CFR 1.38). 
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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 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 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, or by filing an answer in which all of the 

material allegations of fact contained in the complaint are admitted and a 

hearing is not requested, a hearing will be held at 10:00 a.m., local time, on 

the 6th day of May 1964, in Minneapolis, Minnesota, 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 respondents Charles E. Ritten and J. Peter Ritten as floor 

brokers, suspending or revoking the registration of Louis N. Ritten & Co. as 

futures commission merchant, 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 the 

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

Done at Washington, D. C. 

March 26, 1964 

/s/ George L. Mehren 

Assistant Secretary 

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