CFTC Issues Four No-Action Letters Regarding Filing Requirements for CPOs (CFTC Letters 14-51, 14-52, 14-53, 14-54)

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued four separate no-action letters to commodity pool operators ("CPOs") providing relief from Annual Report filing and certification requirements.

CFTC Letter 14-51 granted relief to a CPO of commodity pools from the Annual Report filing and certification requirements in CFTC Rules 4.7(b)(3) and 4.22(d), allowing the CPO to distribute and file a 15-month combined Annual Report covering the period from inception of trading on October 1, 2013 through December 31, 2014.

CFTC Letter 14-52 granted relief to a CPO of commodity pools from the Annual Report filing and certification requirements in CFTC Rules 4.7(b)(3) and 4.22(d), permitting the CPO to file an audited Annual Report for the pools for the 15-month period from January 1, 2013 to March 24, 2014.

CFTC Letter 14-53 granted relief to a CPO from the requirement to file and distribute an annual report with audited financial statements to participants of its commodity pool, pursuant to CFTC Rules 4.7(b)(3) and 4.22(d), provided that the CPO files with the National Futures Association ("NFA") and distributes to its participants unaudited financial statements for the fiscal year 2013 within 90 days of the end of the Pool's 2013 fiscal year.

CFTC Letter 14-54 granted exemptive relief to a CPO from the provisions of CFTC Rule 4.22(d)(1) that the CPO prepare and distribute to its participant, and file with NFA, audited financial statements within the Annual Report for the year ending December 31, 2013. The relief is granted conditioned upon the CPO's distribution and filing with NFA a 2013 Annual Report containing unaudited financial statements, and future Annual Reports in full compliance with CFTC Rules 4.22(c) and (d).

See: CFTC Letter 14-51; CFTC Letter 14-52; CFTC Letter 14-53; CFTC Letter 14-54.