No-action position on commodity pool operator and commodity trading advisor registration for certain private funds and subject to certain conditions, with additional revision to address CPO delegation arrangements.

No-action position on commodity pool operator and commodity trading advisor registration for certain private funds and subject to certain conditions.

The Commodity Futures Trading Commission’s Market Participants Division today announced it has issued a no-action letter to the Structured Finance Association, in the context of qualifying credit risk transfer (CRT) transactions engaged in by their member financial institutions and certain commodity pool operator (CPO) requirements.

No-Action Relief to JSCC from Reg. 39.6(b)(1) and CEA Sec. 4d(f) and 4m(1)

No-action relief was granted to an entity from the requirement to register as a CPO with respect to a commodity pool; provided that, the entity delegates its CPO responsibilities for that pool to a registered CPO, subject to certain conditions.

No-action relief granted to a general partner of a SPE from CPO registration under CEA section 4m(1).

No-action relief was granted to an entity from the requirement to register as a CPO with respect to a commodity pool; provided that, the entity delegates its CPO responsibilities for that pool to a registered CPO, subject to certain conditions.

No-action relief granted to an entity (Ltd.) from CPO registration under CEA Section 4m(1) with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief granted to an entity (LLC) from CPO registration under CEA Section 4m(1) with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

No-Action relief granted to an entity from registering as a CPO or CTA with regard to managing the investing activities of its affiliate, which owns mineral and royalty interests in crude oil and natural gas properties.