Title: 14-160

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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) Filing with NFA an audited annual report of the Trading Vehicle; and (4) Filing with NFA Form CPO-PQR for the Parent. This relief allows the CPO to prepare one audited annual report at the Parent-level and one Form CPO-PQR at the Subsidiary-level for the entire fund complex.