The CFTC's Division of Clearing and Intermediary Oversight provided no-action relief to the general partner of a commodity pool from registering as a CPO and allowed an affiliated, registered CPO ("designee") to serve as the CPO of the pool instead, where, among other things: the general partner and the designee are under common ownership and control; the general partner has delegated all of its management authority to the designee; the general partner does not engage in the solicitation of investors for the pool and does not manage property of the pool; and the general partner and designee executed and submitted to the Division a written acknowledgement of joint and several liability for any violation by either of them of the Act or the Commission's regulations. CFTC Letter No. 10-19.