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Commodity Futures Trading Commission 

CEA CASES 

NAME: LEONARD B. FELDMAN 

DOCKET NUMBER: STIPULATION 116 

DATE: DECEMBER 16, 1970 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Leonard B. Feldman 

Stipulation of Compliance Under the Commodity Exchange Act No. 116 

The Secretary of Agriculture has reason to believe that Leonard B. Feldman 

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 Leonard B. Feldman 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 Leonard B. Feldman for the purposes of this stipulation of compliance 

and administrative proceedings under the Commodity Exchange Act and for such 

purposes only, stipulates the following facts are true: 

(1) Leonard B. Feldman an individual whose address is 110 N. Franklin, Rm. 

421, Chicago, Illinois 60606 is now and was at all times material herein a 

registered floor broker under the Commodity Exchange Act and a member of the 

Chicago Mercantile Exchange, a duly designated contract market under the 

Commodity Exchange Act. 

(2) The futures transactions hereinafter referred to relate to pork belly 

futures contracts on the Chicago Mercantile Exchange. Each of such contracts 

called for the delivery of 30,000 pounds of pork bellies. Such contracts could 

have been used for hedging transactions in interstate commerce in pork bellies, 

or for determining 

the price basis of transactions in interstate commerce in pork bellies, or for 

delivering pork bellies, sold, shipped, or received in interstate commerce. 

(3) On February 17, 1969, Leonard B. Feldman who was acting for his own 

account at Imperial Securities, Inc., sold six contracts of March pork bellies 

to Stuart N. Gimbel who was acting for the accounts of customers of Imperial 

Securities, Inc. Such transactions between these two brokers who were both 

qualified to trade for the same clearing member were reported as being made with 

another floor broker. 

On February 17, 1969, Leonard B. Feldman, acting for his personal account at 

Imperial Securities, Inc., sold three contracts of March pork bellies to 

Lawrence S. Shepard who was also acting for his personal account at Imperial 

Securities, Inc. Such transaction between these two brokers who were both 

qualified to trade for the same clearing member was made with the assistance of 

another floor broker who entered into a wash and accommodation transaction with 

them. 

On February 17, 1969, Leonard B. Feldman, acting for his personal account at 

Imperial Securities, Inc., purchased two contracts of March pork bellies from 

Lawrence S. Shepard who was also acting for his personal account at Imperial 
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Securities, Inc. Such transaction between these two brokers who were qualified 

to trade for the same clearing member was reported as being made with another 

broker. 

On February 17, 1969, Leonard B. Feldman, acting for his own account sold one 

contract of March pork bellies to Lawrence S. Shepard 

who was acting for the account of a customer of Imperial Securities, Inc. Such 

transaction between these two brokers who were qualified to trade for the same 

clearing member was reported as being made with another broker. 

On February 11, 1969, Leonard B. Feldman, acting for his personal account at 

Imperial Securities, Inc., sold four contracts of February pork bellies to 

Michael F. Winner who was acting for the account of a customer of Imperial 

Securities, Inc. Such transaction between two brokers who were qualified to 

trade for the same clearing member was made with the assistance of another 

broker who entered into a wash and accommodation trade with Feldman and Winner. 

The Commodity Exchange Authority has advised Leonard B. Feldman that his 

actions as described above, were in violation of section(s) 4b, 4c and 4g of the 

Commodity Exchange Act and section(s) 1.35 and 1.38 of the regulations under the 

Commodity Exchange Act. 

The said Leonard B. Feldman agrees to desist from such acts and practices in 

the future. He further understands and agrees that this stipulation, which the 

Secretary of Agriculture is accepting only as to the acts and practices set 

forth above, shall be admissible as evidence of such acts and practices in any 

future proceeding based upon acts or practices occurring subsequent to the date 

of his signing of this stipulation of compliance 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 

issue press releases on stipulations of compliance and to make them a matter of 

public record. 

Done at Chicago, Illinois 

this 16 day of Dec 1970 

[SEE SIGNATURE IN ORIGINAL] 

Witnessed by: 

[SEE SIGNATURE IN ORIGINAL] 

[SEE SIGNATURE IN ORIGINAL] 

LOAD-DATE: June 16, 2008 
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