No-Action Position to a SD Regarding the Public Disclosure of Certain Financial Information under SD Financial Reporting Requirements

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.

DCR DSIO Issue Supplemental Advisory Grant of No-Action Relief from 1.56 and 39.13(g)(8)(iii)

Exemptive relief that was provided in CFTC Staff Letters 14-35 and 14-36 with respect to the requirements of Commission regulations 4.21, 4.22, and 4.25 was extended to the successor CPO of the trusts and series in those letters, subject to certain conditions, including the following: (1) the material business terms of the trusts and series do not change; (2) the investment experience of the shareholders does not change; (3) the only material change is the substitution of the CPO; (4) the representations made by the CPO in CFTC Letters 14-35 and 14-36 remain applicable; and (5) the successo

The CPO of a commodity pool organized as a Delaware statutory trust requested relief to provide investors with disclosure documents for certain of the series of the trust separate from the disclosure document for the rest of the trust’s series due to compliance requirements pursuant to securities laws and regulations. The Division granted exemptive relief.

The CPO of a commodity pool organized as a Delaware statutory trust requested relief to provide investors with disclosure documents for certain of the series of the trust separate from the disclosure document for the rest of the trust’s series due to compliance requirements pursuant to securities laws and regulations. The Division granted exemptive relief.

The CPO of four pools organized as Delaware Series Limited Liability Companies requested an interpretation of the use of the term “pool” in Part 4 of the Commission’s regulations to include the individual series of a series limited liability company. The CPO also requested relief to use a tripartite disclosure document that limited certain disclosures to the offered series. DCIO declined to expand the definition of the term “pool” to include a series of a series limited liability company.

The Division of Clearing and Intermediary Oversight granted exemptive relief from certain of the Part 4 regulations to the registered CPO of two commodity pools, whose shares the CPO intended to publicly offer and list for trading on a national securities exchange. As is discussed in the letter, this relief was in the nature of substituted compliance with those regulations.

The Division of Clearing and Intermediary Oversight granted exemptive relief from certain of the Part 4 regulations to the registered CPO of a commodity pool, whose shares the CPO intended to publicly offer and list for trading on a national securities exchange. As is discussed in the letter, this relief was in the nature of substituted compliance with those regulations. Exemptive relief was also provided with respect to future commodity pools with the same structural and operational features as the CPO’s existing pool.

The Division of Clearing and Intermediary Oversight granted exemptive relief from certain of the Part 4 regulations to the registered CPO of two commodity pools, whose shares the CPO intended to publicly offer and list for trading on a national securities exchange. As is discussed in the letter, this relief was in the nature of substituted compliance with those regulations.