No-action positions for commodity pool operators in response to the COVID-19 pandemic

Rescission of CFTC Staff Letter No. 16-47

Exemptive relief granted to a CPO from filing with NFA and distributing to NFA annual reports for certain subsidiary pools, subject to certain conditions.

Exemptive relief granted to a CPO of a fund complex from: (1) Filing with NFA and distributing to the participants of the Intermediate Fund an audited annual report of the Feeder Fund; and (2) Filing with NFA Form CPO-PQR for the Intermediate Fund. This relief allows the CPO to prepare one audited annual report and one CPO-PQR at the Feeder Fund-level for both the Feeder Fund and the Intermediate Fund.

DSIO response to industry questions on Form CPO-PQR FAQ.

DSIO provided a letter that exempts certain commodity trading advisors (CTAs) that are registered, but do not direct any client commodity interest accounts, from reporting on Form CTA-PR.

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

DSIO provided a letter that exempts commodity pool operators that are registered, but only operate pools pursuant to Commission Regulations 4.5 or 4.13(a)(3), from reporting on Form CPO-PQR.

No-action letter permitting, subject to certain conditions, commodity pool operators of certain commodity pools that are non-registered investment companies (“Parent Pools”) that use wholly-owned trading subsidiaries to trade in commodity interests (“Trading Subsidiaries”) to consolidate the annual reports required to be submitted to the National Futures Association (“NFA”) pursuant to Commission regulation 4.7(b) or 4.22(c), as applicable, and the CPO-PQR reports required to be submitted to NFA pursuant to Commission regulation 4.27(c) for the Trading Subsidiaries with those of their Paren

Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that it will not recommend that the Commission take enforcement action against commodity pool operators of registered funds for failure to provide a separate report for their controlled foreign corporations to the National Futures Association pursuant to Commission regulation 4.27(c) and a separate annual report for their controlled foreign corporations to the National Futures Association pursuant to Commission regulation 4.22(c); provided that such commodity pool operators consolidate the reporting for the