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Commodity Futures Trading Commission 

CEA CASES 

NAME: T. C. HENDERSON & CO., INC., AND GEORGE E. MILLER 

DOCKET NUMBER: STIPULATION 100 

DATE: APRIL 1, 1966 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: T. C. Henderson & Co., Inc., and George E. Miller 

Stipulation of Compliance Under the Commodity Exchange Act No. 100 

The Secretary of Agriculture has reason to believe that T. C. Henderson & 

Co., Inc., and George E. Miller have violated the provisions of the Commodity 

Exchange Act (7 U.S.C., Chapter 1) and the regulations of the Secretary of 

Agriculture promulgated thereunder. No complaint with respect to such 

violations has been issued and T. C. Henderson & Co., Inc., and George E. Miller 

are desirous of disposing of this 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, 0.0-0.28). Therefore, T. C. Henderson & Co., 

Inc., and George E. Miller stipulate the following facts are true: 

(1) T. C. Henderson & Co., Inc., is now and was at all times mentioned herein 

a registered futures commission merchant under the Commodity Exchange Act with 

an office and principal place of business at Sixth and Grand Avenue, Des Moines, 

Iowa. 

(2) George E. Miller is now and was at all times mentioned herein an employee 

of T. C. Henderson & Co., Inc. 

(3) The acts and practices on the part of T. C. Henderson & Co., Inc., 

hereinafter described were carried out by George E. Miller in his capacity as an 

employee of T. C. Henderson & Co., Inc., and acting for T. C. Henderson & Co., 

Inc. 

(4) On February 18, 1965, T. C. Henderson & Co., Inc., purchased 200,000 

bushels of November soybean futures for the account of a customer who at the 

time of such purchase held a short November soybean futures position of 450,000 

bushels, 300,000 of which were acquired on February 9, 1965, and 150,000 on 

February 17, 1965. Although T. C. Henderson & Co., Inc., did not receive 

specific close-out instructions from the customer, it failed to apply the 

purchase against the oldest portion of the previously held short position but 

instead applied 150,000 bushels of such purchase to offset the short position 

entered into on February 17, 1965, and only 50,000 bushels to offset a portion 

of the short position entered into on February 9, 1965. 

T. C. Henderson & Co., Inc., and George E. Miller agree to desist from such 

acts and practices in the future. They further understand and agree that this 

stipulation shall be admissible as evidence of such acts and practices in any 

future proceeding based upon acts or practices other than those referred to 

herein which may 

be brought by the Secretary of Agriculture against either of them under the 

provisions of the said act. They also understand that it is the practice of the 
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Commodity Exchange Authority to make stipulations of compliance a matter of 

public record. 

Done at [ILLEGIBLE TEXT] this 

1st day of April, 1966 

T. C. HENDERSON & CO., INC. 

By: [SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

George E. Miller 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
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