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On October 12, 2006 NFA issued a Complaint charging Brandywine with failure to timely file with NFA the annual reports.
On November 13, 2006, Brandywine filed an Answer to the Complaint in which it denied the material allegations contained therein.
On April 12, 2007, Brandywine was ordered to pay a $35,000. On or before July 31, 2007, Brandywine was ordered to file with NFA any and all previously unfiled 2004 and 2005 annual reports for pools that they operated during those years.