13-17
Title: 13-17
The Division of Swap Dealer and Intermediary Oversight provided no-action relief to the general partners of two commodity pools from registering as a CPO under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliated CPO (“designee”) to serve as the CPO of the pools instead, where, among other things: (1) the general partners and the designee are under common ownership and control; (2) the general partners have delegated all of their management authority to the designee; (3) the general partners do not engage in the solicitation of investors for the pools and do not manage pro