Action against Respondents, two companies that originate agriculture commodities, for allegedly holding net positions in the ICE Futures Cotton No. 2 contracts that, in aggregate, exceeded the CFTC’s speculative position limits. The CFTC further alleges that Respondents executed exchange of futures for physical transactions opposite each other’s cotton futures trading accounts, even though their accounts were not independently controlled. Finally, the CFTC alleges that one Defendant submitted a Form 304 that failed to represent all required information accurately, including its short cash sales commitments. Defendants have agreed jointly and severally to pay a civil penalty in the amount of $2 million.