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ARTICLE · 23 OCTOBER 2014

CFTC Staff Issues Revised No-Action Relief From CPO Registration For Certain Delegating CPOs

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On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight of the US Commodity Futures Trading Commission issued a no-action letter.

United StatesFinance and Banking
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A&O Shearman
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Nhung Pham
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On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight ("Division") of the US Commodity Futures Trading Commission ("CFTC") issued a no-action letter ("Letter 14-126")1 providing conditional relief from the requirement to register with the CFTC as a commodity pool operator ("CPO") for certain persons that have delegated their duties as a CPO of a commodity pool ("Delegating CPO") to a permissible third-party CPO ("Designated CPO")

Background

Earlier this year, the Division issued a no-action letter ("Letter 14-69")2 that established a streamlined process by which the Division would grant CPO registration no-action relief to certain Delegating CPOs, provided they and their respective Designated CPOs satisfied several criteria specified in Letter 14-69. Those criteria included, among other things, the requirements that (i) the Delegating CPO have delegated to the Designated CPO all of its investment management authority for the relevant pool,

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