The Division of Swap Dealer and Intermediary Oversight granted no-action relief to a commodity pool operator (“CPO”) of three funds (a publicly-traded Parent, a Subsidiary that is approximately 99% owned by the Parent and approximately 1% owned by fund insiders, and a Trading Vehicle wholly-owned by the Subsidiary) from: (1) Filing with the National Futures Association (“NFA”) and distributing to the insider participants of the Subsidiary an audited annual report of the Subsidiary; (2) Distributing periodic statements of the Subsidiary to the insider participants of the Subsidiary; (3) Fili

The CPO of a commodity pool operating pursuant to an exemption under Regulation 4.7 requested exemptive relief from the requirement in Regulation 4.7(b)(3) and 4.22(d) that the financial statements in the pools annual report be audited. The CPO submitted waivers from all of the pools participants evidencing their consent to the relief requested. DSIO granted relief pursuant to Commission regulations 140.93 and 4.12(a) conditioned upon the filing and distribution of an uncertified Annual Report for fiscal year 2013 that otherwise complies with the provisions of Regulation 4.7(b)(3).

The CPO of two commodity pools operating pursuant to an exemption under Regulation 4.7 requested exemptive relief from the annual report requirement in Regulation 4.7(b)(3) to permit it to file an Annual Report for the pools for the period from their inception of trading, July 19, 2013, to December 31, 2014. The CPO submitted signed subscription documents from all seven participants, acknowledging the terms of the Pools’ offering memorandum, which included the CPO’s intent to file and distribute an 18-month Annual Report for the Pools’ first fiscal year.

Exemption from requirement that a pool’s financial statement be audited by independent public accountants.

The Division of Swap Dealer and Intermediary Oversight granted the exemptive relief provided in CFTC Staff Letter 14-49 for additional commodity pools of that commodity pool operator that satisfied the conditions of that letter.

DSIO provided an exemptive letter that enables commodity pool operators to use additional recordkeepers beyond those enumerated in Commission Regulations 4.7(b)(4) and 4.23(c).

Exemption permitting CPO to file a single Annual Report for the period from inception of trading on September 1, 2013 through the end of fiscal year 2014.

The CPO of a commodity pool operated pursuant to Regulation 4.7 requested relief from the audit requirement in Regulation 4.22(d) for the 2013 fiscal year, explained that the pool had ceased trading as of January 10, 2014, and provided waivers from the pool’s six participants, four of whom are principals or affiliates of the pool’s managing member. The Division granted relief, provided that the CPO distribute and file unaudited financial statements with NFA and provided that the final distribution of pool assets is completed within 14 days of the date of the relief letter.

Exemption permitting CPO to file a single Annual Report for the period from January 1, 2013 through the pool’s permanent cessation of trading on February 28, 2014.

The CPO of an offshore commodity pool requested relief from the requirement in Commission regulation 4.7 that the pools financial statements be prepared in accordance with U.S. GAAP. The CPO requested permission to use Luxembourg GAAP in lieu thereof. The CPO represented that the preparation of the pools financial statements would satisfy the requirements of Commission regulation 4.22(d)(2)(i) with respect to the use of Luxembourg GAAP.