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Commodity Futures Trading Commission 

CEA CASES 

NAME: RICHARD J. SENNOTT AND AUGUST COMENZO 

CITATION: 25 Agric. Dec. 18 

DOCKET NUMBER: 133 

DATE: JANUARY 26, 1966 

DOCUMENT TYPE: DECISION AND ORDER 

(No. 10,312) 

In re RICHARD J. SENNOTT AND AUGUST COMENZO. CEA Docket No. 133. Decided 

January 26, 1966. 

Stipulation as to Richard J. Sennott -- Noncompetitive and offsetting 

transactions -- Suspension of registration and trading privileges

The registration and trading privileges of Richard J. Sennott are suspended 

for a period of 15 days for his activities involving noncompetitive and 

offsetting transactions on the Chicago Board of Trade. 

Mr. Earl L. Saunders for Commodity Exhange Authority. Mayer, Friedlich, Spiess, 

Tierney, Brown & Platt, of Chicago, Ill., for respondent Richard J. Sennott. 

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 by the Assistant Secretary of Agriculture. 

The complaint names as respondents two individuals, Richard J. Sennott and 

August Comenzo. At the time of the violations charged, both respondents were 

registered floor brokers under the Commodity Exchange Act and members of the 

Chicago Board of Trade. The proceeding is concerned with transactions in 

soybean oil or soybean meal futures on the Chicago Board of Trade during the 

period July 11, 1963, through October 27, 1964. The complaint charges that in 

making certain of such transactions respondent Sennott offset customers' orders 

and entered into noncompetitive trades, thereby wilfully violating section 4b(D) 

of the Commodity Exchange Act (7 U.S.C. 6b(D)) and section 1.38 of the 

regulations issued under the act (17 CFR 1.38). Respondent Comenzo is charged 

with making accommodation trades and wash sales, and entering into 

noncompetitive trades, thereby wilfully violating section 4c(A) of the act (7 

U.S.C. 6c (A)) and section 1.38 of the regulations. 

No hearing has been held with respect to either respondent. On January 20, 

1966, respondent Richard J. Sennott submitted a stipulation under section 0.4(b) 

of the rules of practice (17 CFR 0.4 (b)), in which he admits the facts 

hereinafter set forth, waives hearing on the charges, and consents to the entry 

of the order contained herein. 

FINDINGS OF FACT

1. Respondent Richard J. Sennott, an individual whose address is 141 West 

Jackson Boulevard, Chicago, Illinois, is now and was at all times material 

herein a member of the Board of Trade of the City of Chicago and a registered 

floor broker under the Commodity Exchange Act. At all times material herein, 

respondent Sennott was authorized to trade on a discretionary basis in commodity 
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futures for the trading account of Honeymead Trading Corporation, a clearing 

member of the Board of Trade of the City of Chicago. 

2. Respondent August Comenzo was at all times material herein a registered 

floor broker under the Commodity Exchange Act. He was at all times material 

herein a member of the Board of Trade of the City of Chicago. 

3. 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. 

4. The transactions referred to in the complaint relate to contracts for the 

purchase or sale of soybean oil or soybean meal futures on the Chicago Board of 

Trade. Such contracts could have been used for (a) hedging transactions in 

interstate commerce in soybean oil or soybean meal or the products or byproducts 

thereof, or (b) determining the price basis of transactions in interstate 

commerce in soybean oil or soybean meal, or (c) delivering soybean oil or 

soybean meal sold, shipped, or received in interstate commerce for the 

fulfillment of such futures contracts. A soybean oil futures contract on the 

Chicago Board of Trade calls for the delivery of 60,000 pounds of soybean oil 

and a soybean meal futures contract on the Chicago Board of Trade calls for the 

delivery of 100 tons of soybean meal. 

5. In each of the transactions listed below, respondent Richard J. Sennott, 

acting as floor broker, filled a purchase order for his principal, a clearing 

member of the Chicago Board of Trade, by entering into a trade with respondent 

August Comenzo. In each of such transactions, respondent Comenzo, acting as 

floor broker pursuant to an order which he received from respondent Sennott, 

took the sale side of such transaction for the trading account of Honeymead 

Trading Corporation at the price bid by respondent Sennott. 

See original document-page 2 

Quantity Price 

Date (No. of (Meal -- Dollars (Oil -- Cents

1963 Commodity Future Contracts) per Ton) per Pound) 

Sept. 25 Soybean Meal May 1964 11 74.00 Oct. 17 Soybean Oil May 1964 5 9.45

Nov. 5 Soybean Oil Dec. 1963 5 9.65

Nov. 6 Soybean Meal May 1964 7 75.25 Nov. 8 Soybean Oil Jan. 1964 9 10.32

Dec. 19 Soybean Oil Oct. 1964 2 9.53

Dec. 31 Soybean Meal Mar. 1964 15 76.30 

1964 Jan. 2 Soybean Oil Jan. 1964 10 8.00

Jan. 2 Soybean Oil Jan. 1964 15 8.02

6. In each of the transactions listed below, respondent Richard J. Sennott, 

acting as floor broker, filled a sell order for his principal, a clearing member 

of the Chicago Board of Trade, by entering into a trade with respondent August 

Comenzo. In each of such transactions, respondent Comenzo, acting as floor 

broker pursuant to an order which he received from respondent Sennott, took the 

purchase side of such transaction for the trading account of Honeymead Trading 

Corporation at the price offered by respondent Sennott. 

Quantity Price Date (No. of (Meal -- Dollars (Oil -- Cents

1963 Commodity Future Contracts) per Ton) per Pound) 

Oct. 9 Soybean Oil Jan. 1964 23 9.80

Oct. 31 Soybean Meal Dec. 1963 7 73.40 

Nov. 6 Soybean Meal Jan. 1964 6 74.30 

Nov. 21 Soybean Oil Jan. 1964 25 7.96

Dec. 2 Soybean Meal Dec. 1963 5 72.45 

Dec. 23 Soybean Oil May 1964 10 8.68

Dec. 31 Soybean Meal July 1964 15 77.70 
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7. On January 13, 1964, respondent Richard J. Sennott, acting for his own 

account, purchased 1900 tons of March 1964 soybean meal futures at a price of $ 

74.55 per ton by entering into a trade with respondent August Comenzo, and on 

February 27, 1964, respondent Sennott, acting for his own account, purchased 

1600 tons of May 1964 soybean meal futures at a price of $ 70.05 per ton by 

entering into a trade with respondent Comenzo. In each of such transactions, 

respondent Comenzo, acting as floor broker 

pursuant to an order which he received from respondent Sennott, took the sale 

side of such transaction for the trading account of Honeymead Trading 

Corporation at the price bid by respondent Sennott. 

8. Each of the transactions described in Findings of Fact numbered 5, 6 and 7 

hereof was a noncompetitive purchase and sale of a commodity for future 

delivery, and in each of the transactions described in Findings of Fact numbered 

5 and 6 hereof respondent Sennott filled orders of his customers by offset. 

CONCLUSIONS

The facts admitted by respondent Sennott in his stipulation have been adopted 

as the findings herein. By reason of these findings, it is concluded that 

respondent Sennott wilfully violated section 4b(D) of the Commodity Exchange Act 

(7 U.S.C. 6b(D)) and section 1.38 of the regulations issued under the Act (17 

CFR 1.38). 

The complainant states that the administrative officials of the Commodity 

Exchange Authority have carefully considered the proposed stipulation and order, 

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

entry of such an order would constitute a satisfactory disposition of the case 

as against respondent Sennott, 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 Richard J. Sennott as a floor broker is hereby 

suspended for a period of fifteen (15) days, effective on the twentieth day 

after the date of entry of this order, and all contract markets shall refuse all 

trading privileges to said Richard J. Sennott for the said period of fifteen 

(15) days, such refusal to apply to all trading done and all positions held by 

him, directly or indirectly. 

A copy of this decision and order shall be served upon each of the parties 

and upon each contract market. 

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