The CEA prohibits fraudulent and manipulative conduct in connection with commodity futures transactions. Eventually, Congress created the CFTC and entrusted it with sweeping authority to implement the CEA. The CFTC promulgated a regulation in 1976 that allowed it to adjudicate counterclaims arising out of the transaction or events set forth in a complaint. Schor and Mortgage Services of America, Inc. invoked the CFTC's reparations jurisdiction by filing complaints against Conti Commodity Services, Inc and its employee Richard Sandor. Schor had an account with them and claimed that they violated the CEA. Before receiving notice that Schor had commenced a reparations action, Conti filed a diversity action to recover the debit balance in Schor's account. Schor counterclaimed. Schor then moved to dismiss indicating that the reparations action would resolve the matters. The District Court declined to stay or dismiss, but Conti voluntarily dismissed and presented its debit balance claim as a counterclaim in the CFTC action. The administrative law judge ruled in Conti's favor, and then Schor challenged CFTC's statutory authority to adjudicate Conti's counterclaim. The decision became final and then appealed. The Appeals Court sua sponte raised the question whether CFTC could constitutionally adjudicate Conti's counterclaims. The decision was upheld, but Conti's counterclaim was dismissed. The Supreme Court granted certiorari.