The CFTC fined a provisionally registered swap dealer ("SD") for submitting inaccurate large trader reports ("LTRs") for physical commodity swap positions.
The CFTC Order stated that the LTRs contained multiple errors, including missing data and data presented in a format inconsistent with CFTC requirements.
The CFTC Order required the SD to pay a $400,000 civil monetary penalty and cease and desist from further violations of the specified regulations.
In a relevant memorandum, Cadwalader attorneys Paul Pantano, Anthony Mansfield, Jonathan Flynn and Natalie Mitchell analyzed the CFTC's "trend toward more aggressive enforcement" of violations of the Swaps LTR rule, and provided a summary of recent CFTC penalties for these violations. The memorandum notes that "compliance professionals should continue to review their reporting processes, including Swaps LTR, to confirm that they conform to CFTC rules."
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