The CFTC Division of Swap Dealer and Intermediary Oversight granted no-action relief to two CPOs from registration, provided that each delegates its responsibilities under CEA Section 4m(1) to a registered CPO, subject to certain conditions. (See here and here for the no-action letters.)
Commentary / Bob Zwirb
The CFTC has responded frequently to requests to provide serial relief to CPOs for common fact situations (note previous commentary on the issue). Add to that now the need to provide "the same relief" to the same parties they previously received for different pools they operate.
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