Subject to the conditions outlined in the letter, the Division of Swap Dealer and Intermediary Oversight (DSIO) granted no-action relief from commodity pool operator (CPO) and commodity trading advisor (CTA) registration to a group of five private universities with respect to the commingled accounts and collective investment vehicles they operate to manage assets belonging to their endowments, graduate and professional schools, and other university supporting organizations, as well as multiple charitable planned giving account structures offered to alumni and other donors.