Rule 4.7(a) - Exemptive Relief for CPO;
The Division of Trading & Markets confirmed an exemption from the requirements of Rules 4.21, 4.22(a) and (b), 4.25, and 4.26 that was previously granted to a registered CPO despite a change in the ownership composition of a pool operated by the CPO and granted an exemption to the CPO to permit the participants in a pool, some of whom do not meet the QEP criteria, to allocate a portion of their investments to a second Rule 4.7 pool operated by the CPO. The first pool was formed as a trading vehicle for the principals and employees of the CPO and its affiliates. The CPO was seeking to allow one limited partner to transfer her interest to her husband and to allow two other limited partners, one former employee and the spouse of another former employee, to maintain their investments. With respect to the second pool, the relief was granted based upon representations that all of the participants were involved in the trading or management of the pool or were related to someone who was so involved.