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The CFTC entered an order and simultaneously settled charges against an Australia-based financial services company for failing to comply with the obligation to submit accurate large trader reports ("LTRs") for physical commodity swap positions. This failure violated Section 4s(f) of the CEA and CFTC Rules 20. 4 and 20.7. The order states that the financial services company (i) did not identify any underlying commodity, (ii) routinely populated the field for "Commodity Reference Price" in a format other than the one provided by the CFTC's Guidebook for Part 20 Reports , (iii) reported certain