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On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued a no-action letter (“Letter 14-126”) providing conditional relief from the requirement to register with the CFTC as a commodity pool operator (“CPO”) for certain persons that have delegated their duties as a CPO of a commodity pool (“Delegating CPO”) to a permissible third-party CPO (“Designated CPO”).