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.

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 relief granted to an entity from CPO registration with respect to several commodity pools for which it serves as trustee; provided, that it delegates the CPO responsibilities to a registered CPO, subject to certain conditions.

No-Action Relief for Investment Pools Investing in Certain Securitization Vehicles Formed Prior to October 12, 2012.

The Division of Swap Dealer and Intermediary Oversight issued a letter providing additional guidance to securitization vehicles regarding whether they may be excluded from the definition of commodity pool. The Division also stated that it will not recommend that the Commission take enforcement action against the commodity pool operators of securitization vehicles that have not and will not issue new securities on or after October 12, 2012.

No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Mortgage Real Estate Investment Trusts.