The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) is introducing a streamlined approach for requests for registration of no-action relief from commodity pool operators (CPO) who delegate certain activities to a registered CPO.

The DSIO proposal does not provide CPO registration relief. 
 
Rather, it establishes a streamlined approach under which DSIO will consider requests for no-action relief from CPO registration and the form of request for relief a CPO must submit under that approach.
 
DSIO will issue individual responses to each requestor seeking relief.
 
Under this streamlined approach, the relief would be limited to certain circumstances and subject to a number of conditions, including that the delegating CPO represent in its form of request that certain specified criteria are met. 
 
However, DSIO intends to continue to consider requests for CPO registration relief involving delegating CPOs where the specified criteria set forth in the letter cannot be met.  
 
The streamlined approach is intended to allow DSIO to more efficiently address the numerous pending and expected requests for relief from delegating CPOs who meet the qualifying criteria.