CFTC Issues No-Action Letter Providing Relief to CPOs from Reporting Requirement (CFTC Letter 14-24)
The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a letter providing time-limited no-action relief to commodity pool operators ("CPOs") that requested exemptions regarding annual reports.
CFTC Letter 14-24 provides no-action relief to the CPO of a commodity pool from CFTC Rule 4.7(b)(3) ("Relief Available to CPOs") and Rule 4.22(d) ("Reporting to Pool Participants"), both of which require that the CPO distribute to its participants, and file with the National Futures Association ("NFA"), an Annual Report within 90 days of the close of the Pool's fiscal year.
The letter states that the relief is not waived entirely but, rather, that the information which would have been contained in the Pool's 2013 Annual Report should be combined with the Pool's 2014 Annual Report, creating a 15-month combined Annual Report covering the period from the Pool's inception, October 1, 2013, through December 31, 2014.
See:CFTC Letter 14-24.Related news: CFTC Issues Two No-Action Letters Providing Relief to CPOS from Reporting Requirements (CFTC Letters 14-22 and 14-23) (February 28, 2014).