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Commodity Futures Trading Commission 

CEA CASES 

NAME: CHARLES KEESHIN, INC., CHARLES KEESHIN, SEYMOUR M. KEESHIN, AND HAROLD 

VISION 

DOCKET NUMBER: 89 

DATE: NOVEMBER 6, 1958 

DOCUMENT TYPE: COMPLAINT 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Charles Keeshin, Inc., Charles Keeshin, Seymour M. Keeshin, and Harold 

Vision, Respondents 

CEA Docket No. 89 

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

Act 

There is reason to believe that the respondents, Charles Keeshin, Inc., 

Charles Keeshin, Seymour M. Keeshin, and Harold Vision have violated the 

provisions of the Commodity Exchange Act (7 U.S.C. 1952 ed., Chapter 1), and the 

rules and regulations of the Secretary of Agriculture made pursuant thereto (17 

CFR, Part I), and in accordance with the provisions of section 6(b) of the said 

act (7 U.S.C. 1952 ed., § 9), this complaint and notice of hearing is issued 

alleging as follows: 

I 

Respondent Charles Keeshin, Inc., a corporation organized under the laws of 

the State of Illinois with its principal office and place of business at 1019 

West Fulton Street, Chicago, Illinois, was at all times material to this 

complaint a registered futures commission merchant under the Commodity Exchange 

Act, a clearing member of the Chicago Mercantile Exchange, and a member of the 

New York Mercantile Exchange. 

II 

Respondent Charles Keeshin, an individual, whose address is 2933 Sheridan 

Road, Chicago, Illinois, was at all times material to this complaint chairman of 

the board of directors and treasurer of the respondent corporation, a registered 

floor broker under the Commodity Exchange Act, a member of the Chicago 

Mercantile Exchange, and a member of the New York Mercantile Exchange. 

III 

Respondent Seymour M. Keeshin, an individual, whose address is 4300 Marine 

Drive, Chicago, Illinois, was et all times material to this complaint president 

of the respondent corporation. 

IV 

Respondent Harold Vision, an individual, whose address is 143 North Parkside 

Avenue, Chicago, Illinois, was at all times material to this complaint secretary 

of the respondent corporation, a registered floor broker under the Commodity 

Exchange Act, and a member of the Chicago Mercantile Exchange. 

V 

The acts hereinafter described were initiated and carried out under the 

supervision and direction of respondents Charles Keeshin, Seymour M. Keeshin, 
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and Harold Vision, acting in their capacities as officers of the respondent 

corporation. 

VI 

a. At all times between August 1, 1958, and September 9, 1958, inclusive, the 

respondent corporation had on its books accounts of customers who were trading 

in commodity futures subject to the Commodity Exchange Act and the rules and 

regulations issued thereunder, and had to its credit with a bank or with the 

Clearing House of the Chicago Mercantile Exchange varying sums of money held in 

segregated accounts and identified as customers' funds, representing deposits of 

margin by and trading profits belonging to such customers. 

b. On 25 business days during the period August 1, 1958, through September 9, 

1958, inclusive, the respondent corporation was undersegregated in amounts 

ranging from $ 6,822.00 to $ 62,530.40 -- that is, on the 25 days mentioned the 

total amount of customers' funds held in segregation as above described, was 

from $ 6,822.00 to $ 62,530.40 less than the amount necessary to pay all credits 

and equities due to such customers. 

c. On each business day during the above period, except on August 7, 1958, 

and September 9, 1958, the respondent corporation prepared and kept a record 

purporting to show the amount required to be held in segregation, and the amount 

segregated, which record indicated that the respondent corporation had excess 

funds in segregation in amounts ranging from $ 473.60 to $ 24,029.10, whereas, 

in truth and in fact, the said corporation was undersegregated as specified 

above. 

On August 7, 1958, and September 9, 1958, no record of funds in segregation was 

prepared. 

By reason of such acts, the respondent corporation knowingly failed to treat 

and deal with customers' funds as belonging to such customers, failed to 

segregate and to account separately for such funds, used such funds to margin 

and guarantee the trades and secure and extend the credit of customers other 

than those for whom such funds were held, commingled customers' funds with funds 

belonging to the respondent corporation, and prepared and kept false records 

with respect to customers' funds, all in willful violation of sections 4d(2) and 

4g of the Commodity Exchange Act (7 U.S.C. 1952 ed., §§ 6d(2), 6g), and sections 

1.20, 1.21 and 1.22 of the rules and regulations (17 CFR 1.20, 1.21, 1.22). 

Therefore, the said respondents Charles Keeshin, Inc., Charles Keeshin, 

Seymour M. Keeshin, and Harold Vision are hereby notified to be and appear at a 

hearing to be held at 10:00 a.m., local time, on the 16th day of December 1958, 

in Room 1200, Board of Trade Building, 141 West Jackson Boulevard, Chicago, 

Illinois, before a referee designated to conduct such hearing, and then and 

there show cause, if any there be, why an order should not be made suspending 

or revoking the registration of respondent Charles Keeshin, Inc., as a futures 

commission merchant, suspending or revoking the registrations of Charles Keeshin 

and Harold Vision as floor brokers, and directing that all contract markets 

refuse all trading privileges to each of respondents for such period of time as 

may be determined. 

The respondents will have twenty (20) days after the receipt of this notice 

of hearing in which to file with the Hearing Clerk, United States Department of 

Agriculture, Washington 25, D. C., an answer with an original and seven copies, 

fully and completely stating the nature of the defense and admitting or denying 

specifically and in detail each material and relevant allegation of this 

complaint. Allegations that are not answered will be deemed admitted for the 

purpose of this proceeding. 
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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., this 

6th day of November 1958. 

/s/ E. L. Peterson 

E. L. Peterson 

Acting Secretary 

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