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Commodity Futures Trading Commission 

CEA CASES 

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

CITATION: 23 Agric. Dec. 747 

DOCKET NUMBER: 118 

DATE: JULY 16, 1964 

DOCUMENT TYPE: DECISION AND ORDER 

(No. 9201) 

In re CHARLES E. RITTEN, J. PETER RITTEN AND LOUIS N. RITTEN & Co. CEA Docket 

No. 118. Decided July 16, 1964. 

Bucketing Orders -- Fictitious, Noncompetitive and Wash Transactions -- 

Denial of Trading Privileges -- Suspension of Registrations -- Consent

The activities of respondents involving bucketing customers' orders, and 

entering into or recording fictitious, noncompetitive and wash transactions in 

grain futures are violations of the act for which suspension of registrations 

and denial of trading privileges are ordered. 

Mr. Earl L. Saunders for Commodity Exchange Authority. Mr. Patrick F. Flaherty,

of Minneapolis, Minnesota, and Mr. Harold P. Green, of Washington, D.C., for 

respondents. 

Decision by Thomas J. Flavin, Judicial Officer

PRELIMINARY STATEMENT

This is an administrative proceeding under the Commodity Exchange Act (7 

U.S.C. Chapter 1), instituted by a complaint filed March 26, 1964, by an 

Assistant Secretary of Agriculture. The complaint alleges that the respondents 

violated sections 4b(D) and 4c(A) of the Act (7 U.S.C. §§ 6b(D) and 6c(A)), and 

section 1.38 of the regulations issued under the Act (17 CFR 1.38). 

No hearing has been held with respect to this proceeding. On July 6, 1964, 

the respondents withdrew the answers which they had previously filed and 

submitted a stipulation under section 0.4(b) of the rules of practice (17 CFR 

0.4(b)), in which they admit the facts hereinafter set forth under the "Findings 

of Fact," waive hearing on the charges in the complaint, and consent to the 

entry of the order contained herein. 

FINDINGS OF FACT

1. 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. 

2. 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. 

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

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

4. 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. 

5. The transactions referred to herein 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 grain or the products or 

by-products 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. 

6. 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. 

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. 

7. 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 (Thous. (Cents per of bu.) bushel) Clearing Member Customer 

Oct. 29 May '63 20 232-7/8 Louis N. C. E. Ritten 

Ritten & Co. 

Oct. 29 Dec. '62 10 232-1/2 Louis N. C. E. Ritten 

Ritten & Co. Nov. 15 May '63 10 233-7/8 F. H. Peavey Louis N. 

& Company Ritten & Co. 

Nov. 16 May '63 20 234-7/8 F. H. Peavey Louis N. 

& Company Ritten & Co. 

Nov. 21 Dec. '62 10 234-3/4 Louis N. C. E. Ritten 

Ritten & Co. Date Selling 

1962 Clearing 

Member Customer 

Oct. 29 F. H. Peavey Louis N. 

& Company Ritten & Co.
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Date Future Quantity Price *Buying 

1962 (Thous. (Cents per of bu.) bushel) Clearing 

 Member Customer 

Oct. 29 F. H. Peavey Louis N. 

& Company Ritten & Co.

Nov. 15 Louis N. C. E. Ritten

Ritten & Co. Nov. 16 Louis N. C. E. Ritten

Ritten & Co. 

Nov. 21 F. H. Peavey Louis N. 

& Company Ritten & Co.

8. 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 actuually had taken place, but, rather, respondent J. Peter 

Ritten merely "carded" such transaction. 

9. 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 respondents Louis N. Ritten & Co., when ,in truth and in fact, both 

individual respondent 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.>100> >101> 

Trades Made by Individual 

Repondents for the Account of 

Louis N. Ritten & Co. at F. H. 

Peavey & Company 

Floor 

Date Future Quantity Price Broker 

1962 Bought Sold (Thousands (Cents per 

of bushels) bushel) 

Bought Sold 

Oct. 4 May '63 5 233 3/4 C. E. Ritten

Oct. 9 Dec. '62 5 231 " " 

Oct. 12 May '63 10 232 1/2 " " 

Nov. 7 May '63 10 234 1/4 " " 

Nov. 12 Dec. '62 5 235 1/4 " " 

Nov. 12 May '63 5 233 7/8 " " 

Nov. 13 May '63 5 234 1/4 " " 

Nov. 13 Dec. '62 5 235 7/8 " " 

Nov. 13 Dec. '62 5 235 3/4 " " 

Nov. 16 Dec. '62 2 236 1/2 " " 

Nov. 16 May '63 10 235 " " 

Nov. 20 Dec. '62 20 236 1/2 J. P. Ritten

Nov. 20 Dec. '62 30 236 5/8 C. E. Ritten

Nov. 21 Dec. '62 5 234 3/8 " " 

Nov. 30 May '63 5 234 1/2 " " 

Dec. 5 May '63 5 234 7/8 " " 

Dec. 6 May '63 5 235 1/4 J. P. Ritten
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Trades Made by Individual 

 Repondents for the Account of Louis N. Ritten & Co. at F. H. Peavey & Company 

 Floor 

Date Future Quantity Price Broker 

1962 Bought Sold 

 (Thousands (Cents per 

 of bushels) bushel) 

 Bought Sold 

Dec. 7 May '63 5 234 3/4 C. E. Ritten

Dec. 17 May '63 10 234 1/2 " " 

Dec. 19 May '63 5 233 1/8 " " 

Dec. 20 May '63 4 232 3/4 " " 

Opposite Side of Trade 

Floor Purported 

Date Broker Account 

1962 Oct. 4 J. P. Ritten J. P. Ritten

Oct. 9 " " " " 

Oct. 12 " " " " 

Nov. 7 " " " " 

Nov. 12 " " " " 

Nov. 12 " " " " 

Nov. 13 " " " " 

Nov. 13 " " " " 

Nov. 13 " " " " 

Nov. 16 " " " " 

Nov. 16 " " " " 

Nov. 20 C. E. Ritten C. E. Ritten

Nov. 20 J. P. Ritten J. P. Ritten

Nov. 21 " " " " 

Nov. 30 " " " " 

Dec. 5 " " " " 

Dec. 6 C. E. Ritten C. E. Ritten

Dec. 7 J. P. Ritten J. P. Ritten

Dec. 17 " " C. E. Ritten

Dec. 19 " " J. P. Ritten

Dec. 20 " " " " 

10. 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. 

11. 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 
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the opposite clearing member, when, in truth and fact, no such trade actually 

had taken place. 

CONCLUSIONS

By reason of the facts set forth in the Findings of Fact, it is concluded 

that respondents violated sections 4b(D) and 4c(A) of the Commodity Exchange Act 

(7 U.S.C. §§ 6b(D and 6c(A)), and section 1.38 of the regulations issued under 

the Act (17 CFR 1.38). 

Complainant states that the administrative officials of the Commodity 

Exchange Authority have carefully considered the proposed stipulation and order, 

and that they believe that the proposed sanctions are adequate and that the 

prompt entry, without further proceedings, of the order to which respondents 

have consented will constitute a satisfactory disposition of the case, serve the 

public interest, and effectuate the purposes of the Commodity Exchange Act. 

Complainant recommends, therefore, that the stipulation and waiver submitted by 

respondents be accepted and that the proposed order be issued. It is so 

concluded. 

ORDER

The registration of respondent Charles E. Ritten as a floor broker is hereby 

suspended for a period of 30 days, effective on the 15th day after the date of 

entry of this order, and all contract markets shall refuse all trading 

privileges to the said Charles E. Ritten for the said period of 30 days, such 

refusal to apply to all trading done and positions held by the said Charles E. 

Ritten directly or indirectly. 

The registration of respondent J. Peter Ritten as a floor broker is hereby 

suspended for a period of 20 days, effective on 

the 15th day after the date of entry of this order, and all contract markets 

shall refuse all trading privileges to the said J. Peter Ritten for the said 

period of 20 days, such refusal to apply to all trading done and positions held 

by the said J. Peter Ritten directly or indirectly. 

Effective on the 15th day after the date of entry of this order, all contract 

markets shall refuse all trading privileges to respondent Louis N. Ritten & Co., 

in connection with the said firm's own account, for a period of 30 days, such 

refusal to apply to all trading done and positions held by the said Louis N. 

Ritten & Co. for its own account directly or indirectly, and effective on the 

same date, the registration of respondent Louis N. Ritten & Co. as a futures 

commission merchant is hereby suspended for a period of 30 days, Provided, 

However, that the aforesaid suspension of registration as futures commission 

merchant shall not become effective unless, after complaint, and hearing in 

accordance with established procedure, respondent Louis N. Ritten & 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 Louis N. Ritten & Co., issue a supplemental 

order making effective forthwith the aforesaid suspension of registration as 

futures commission merchant. 

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

and on each contract market. 

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