Form of Reply for CFTC Letter No. 14-75, 14-76, 14-77, 14-78, 14-79, 14-80, 14-81, 14-82, 14-83, and 14-84

Form of Reply for CFTC Letter No. 14-75, 14-76, 14-77, 14-78, 14-79, 14-80, 14-81, 14-82, 14-83, and 14-84

Form of Reply for CFTC Letter No. 14-75, 14-76, 14-77, 14-78, 14-79, 14-80, 14-81, 14-82, 14-83, and 14-84

Form of Reply for CFTC Letter No. 14-75, 14-76, 14-77, 14-78, 14-79, 14-80, 14-81, 14-82, 14-83, and 14-84

The Division of Swap Dealer and Intermediary Oversight granted no-action relief from the requirement to register as a commodity pool operator to a Delegating CPO that requested the relief in accordance with the streamlined approach described in CFTC Staff Letter No. 14-69.

Update: This letter has been replaced by letter 14-126.

The Division of Swap Dealer and Intermediary Oversight confirmed the availability of Staff Letter 00-10, which provided CPO registration relief to a universitys cooperative extension service, its agents and employees, permitting them to offer courses that would allow certain students to trade commodity interests through participation in a trading club, notwithstanding certain amendments to the course and trading club criteria.

The Division of Swap Dealer and Intermediary Oversight (Division) took a CPO registration no-action position with respect to the operation of certain collective trading vehicles by either of two corporations (A and B) entirely controlled by a non-profit corporation (C) that is the coordinating organization for a denomination’s churches.

The Division of Swap Dealer and Intermediary Oversight granted no-action relief from the registration requirement of Section 4m(1) of the Commodity Exchange Act to a commodity pool operator (“CPO”) of a pool, the investors of which are the owner of the general partner and CPO of the pool, his family investment vehicle, and his close business associates who were involved in developing the pool’s trading algorithm.

DSIO granted no action relief with respect to registration as a CPO for an entity acting as a directed trustee with respect to a commodity pool.