The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the trustee of a pension plan group trust comprised solely of pension plans that are “not construed to be pools” under Regulation 4.5(a)(4)(i)-(iii).

The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the Board of Trustees of a pension plan group trust comprised of two plans: one that is a “qualifying entity” under Regulation 4.5, and another that is “not construed to be a pool” under that same rule.

The Division of Swap Dealer and Intermediary Oversight took a CPO and CTA registration no-action position with respect to a registered investment adviser that acted as the sponsor and investment manager for a pension plan group trust. Each of the plans participating in the group trust was within the categories of plans excluded under Regulation 4.5 from the “pool” definition.