On December 21st, DSIO advised it will not recommend enforcement action against the commodity pool operators of investment pools that invest in securitization vehicles that comply with the terms of the no-action relief set forth in CFTC Letter No. 12-45. CFTC Letter No. 12-45 only provided no-action relief to the operators of legacy securitization vehicles but did not address whether investment in such vehicles would result in the operator of the investor fund being required to register as a commodity pool operator. The Division believes that the operator of a fund that invests in a legacy securitization vehicle that satisfies the criteria of the no-action relief provided in the CFTC Letter No. 12-45 should be entitled to relief comparable to that of the underlying legacy securitization vehicle. Accordingly, the Division will not recommend that the Commission take enforcement action against the operator of a fund that invests in a legacy securitization vehicle whose operator is entitled to no-action relief under the terms of CFTC Letter No. 12-45, and who otherwise would not be required to register as a commodity pool operator, for failure to register as a commodity pool operator with the Commission. CFTC Letter No. 12-67.