The Division of Swap Dealer and Intermediary Oversight provided no-action relief to the managing member of a commodity pool from registering as a CPO under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliate (“designee”) to serve as the CPO of the pool instead, where, among other things: (1) the managing member and the designee are under common ownership and control; (2) the managing member has delegated all of its management authority to the designee; (3) the managing member does not engage in the solicitation of investors for the pool and does not manage property of the pool; and (4) the managing member and designee executed and submitted to the Division a written acknowledgement by which they undertake joint and several liability for any violation of the Act or the Commission’s regulations. The relief was subject to the conditions that the designee becomes and remains registered as a CPO and serves as CPO of the pool.