While Goldman has backreported more than 20 million swaps to date, the CFTC believes this figure significantly underestimates the true scope of the swap data reporting failures at Goldman. In addition, the order states, on more than one million occasions since 2013, Goldman provided counterparties with PTMMMs that were inaccurate or failed to provide a PTMMM entirely. The order recognizes Goldman's substantial cooperation with the Division of Enforcement's investigation in the form of a reduced civil monetary penalty. The CFTC thanks and acknowledges the assistance of the National Futures Association in this matter. The Market Participants Division, the Division of Market Oversight, the Division of Data, and the Division of Clearing and Risk also assisted with the Goldman case.