Staff of the Division of Swap Dealer and Intermediary Oversight exempted a state university organized investment management company and individual directors from having to register as commodity pool operators in connection with their roles ultimately overseeing three funds operated on behalf of university affiliates, supporting organizations and foundations that currently or may in the future invest in commodity interests. Staff indicated that relief was warranted because the management company and directors “share an aligned interest and common goal with the Fund participants.” Also, neither the management company nor the directors market any of the funds to the public, and the universe of possible fund participants is sufficiently small due to the funds being limited to persons affiliated with the university.