CFTC Expedited No-Action Relief for CPO Delegation On May 12, 2014, the CFTC issued registration no-action relief on an expedited basis for CPOs who delegate certain activities to a registered CPO.  Under this streamlined approach, the delegating CPO must represent in its request letter that it satisfies the applicable criteria.  Such criteria includes, in part, representations that the delegating CPO: (1) has delegated to the designated CPO all of its investment management authority with respect to the commodity pool via a legally binding document, (2) does not participate in the solicitation of participants for the commodity pool, (3) does not…

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