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if we call it after, we might receive a "fresh" transaction from `broadcast_tx_sync` before old transactions (which were not committed). Refs #1091 ``` Commit is called with a lock on the mempool, meaning no calls to CheckTx can start. However, since CheckTx is called async in the mempool connection, some CheckTx might have already "sailed", when the lock is released in the mempool and Commit proceeds. Then, that spurious CheckTx has not yet "begun" in the ABCI app (stuck in transport?). Instead, ABCI app manages to start to process the Commit. Next, the spurious, "sailed" CheckTx happens in the wrong place. ```