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Interpretative Letters

Interpretative Letters
05-13 PDF Image; Rule 4.14 (a)(8); Interpretation
The Division of Clearing and Intermediary Oversight affirmed that a registered investment adviser could claim CTA registration exemption under Rule 4.14(a)(8) with respect to certain of its advisory activities while simultaneously relying upon the CTA registration exemption provided by Section 4m(3) of the Commodity Exchange Act. For purposes of the letter, it was not necessary for the Division to define or otherwise interpret the criteria of Section 4m(3), or to make any determination whether the requester met those criteria.