Page 17 - 期货和衍生品行业监管动态（2023年6月刊）

期货和衍生品行业监管动态

Act and CFTC regulations, as charged. The order also permanently prohibits Easterday

from trading on or subject to the rules of any CFTC-registered entity and from engaging

in any activities requiring CFTC registration.

The order stems from a CFTC complaint filed on March 31, 2021, charging Cody

Easterday and Easterday Ranches, Inc. with the sale of more than 200,000 non-existent

head of cattle to a beef processor, making false statements to an exchange, and

exceeding the number of contracts permitted by exchange-set position limits. A consent

order was entered against Easterday Ranches on December 17, 2021. [See CFTC Press

Release Nos. 8425-21, 8471-21]

“There’s a saying about people who pretend to be something they’re not: they’re

‘all hat and no cattle.’ That perfectly describes Easterday,” said Director of Enforcement

Ian McGinley. “Easterday cheated his best customer by lying about non-existent cattle,

lied to an exchange, and broke exchange rules. The CFTC remains focused on

protecting our agricultural markets and will aggressively prosecute cases to ensure that

bad actors are barred from those markets.”

Case Background

According to the order, from approximately October 2016 to November 2020,

Easterday caused Easterday Ranches to submit false invoices and reimbursement

requests relating to more than 200,000 head of cattle that it never purchased or raised

on the processor’s behalf. Through the use of fraudulent invoices and reimbursement

requests, Easterday Ranches received more than $233 million to which it was not

entitled.

In addition, the order finds that Easterday caused Easterday Ranches to report false

or misleading information concerning its cattle inventory, purchases, and sales to the

Chicago Mercantile Exchange in at least two hedge exemption applications seeking

permission to exceed the exchange’s position limits. These false statements to the

exchange were made in 2017 and 2018 to avoid disciplinary actions and scrutiny when

Easterday Ranches exceeded exchange-based position limits in the live cattle and feeder

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