This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4. 

The staff letter confirms that, for purposes of applying the position limits set forth in CFTC Regulation 150.2, when an institutional investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation with respect to their investment in a fund, the institutional investor is not required to look through its investment in a fund to aggregate commodity interest positions of an underlying portfolio company in which the institutional investor may hold a 10 percent or greater indirect interest (via its investment in the fund).  

The Division of Market Oversight provides time-limited no-action relief from certain aggregation requirements under its position limits regime.

Time-Limited No-Action Relief, until 12:01 a.m. eastern standard time on August 14, 2017, from compliance with the notice filing requirements of Commission Regulation 150.4(c), as effective February 14, 2017.