Two families, whose patriarchs have been business partners of a large, publicly traded U.S. retailer since the company’s founding over forty years ago, requested no-action relief from CPO registration on behalf of the families, the S corporation founded solely to provide services to the families, and the S corporation’s employees, with regard to funds operated by the families that may invest in commodity interests. Based on the facts presented, including the longstanding business and personal relationships between the families, the Division granted the requested no-action relief from CPO registration.