CFTC Guidance on CPO Delegation Process

CW Logo SmallDear Friends,

On May 12, 2014, the CFTC announced a streamlined approach for considering requests for no-action relief with respect to CPOs who delegate certain activities to a registered CPO (e.g. GPs of limited partnerships who delegate CPO authority to a registered investment manager).

Each delegating CPO must submit a letter certifying it meets certain criteria outlined in the release.  However, the CFTC will continue to consider requests for CPO registration relief for delegating CPOs in instances where the criteria cannot be met. This approach is expected to allow the CFTC to more efficiently respond to the numerous pending and expected requests for relief from delegating CPOs who meet the criteria set forth in the letter.

Please click here for a link to the release and template of the letter that must be submitted to the CFTC. Please feel free to contact us with any questions at (212) 867-0200 or email us at

Thank you,


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