Exemptive relief permitting a limited number of non-QEP senior employees of the CPO to be treated as QEPs, subject to several specific conditions, for purposes of investing in employee securities companies the CPO operates as 4.7 pools.

Exemptive relief from the requirement in Regulations 4.7(b)(3) and 4.22(c) to provide an audited Annual Report and Financial Statements when liquidating a commodity pool, if the pool instead provides a combined 13-month Annual Report and Financial Statements.

No-action position from CPO/CTA registration granted to an entity that uses foreign exchange swaps in managing the risks of its biopharmaceutical royalties business.

Exemptive relief for a CPO from the requirement to provide quarterly account statements within 30 days of the end of each quarter for certain pools, provided that the CPO provides monthly account statements within 45 days of the end of each month for such pool.

Exemptive relief for a CPO from the requirement to provide quarterly account statements within 30 days of the end of each quarter for one of its pools, provided that the CPO provides monthly account statements within 45 days of the end of each month for such pool.

No-action relief granted from CPO and CTA registration to an entity that uses swaps in connection with its acquisition of biopharmaceutical royalties.

No-action positions for commodity pool operators in response to the COVID-19 pandemic

No-action relief was granted to an entity from the requirement to register as a CPO with respect to a commodity pool; provided that, the entity delegates its CPO responsibilities for that pool to a registered CPO, subject to certain conditions.

Interpretative relief granted that states that a pool that is only funded and traded by two brothers is not a commodity pool

The Division issued an interpretation of CEA Section 1a(10) and Regulation 4.10(d), both of which define the term “commodity pool,” which will permit wholly owned subsidiaries of a single life insurance company to contribute their general account assets to a single vehicle formed by them, and will permit the vehicle to invest directly or indirectly in commodity interests without being deemed a commodity pool.