The CFTC's Division of Clearing and Intermediary Oversight took a no-action position in response to a request for relief from the commodity pool operator registration requirements of the Commodity Exchange Act submitted by the independent trustees of a commodity pool where the independent trustees had no authority to perform CPO functions, the independent trustees were appointed solely to comply with audit committee requirements under the Sarbanes Oxley Act and exchange listing requirements, and a separate registered CPO was authorized to perform all commodity pool operator functions. The Division further granted exemptive relief from certain of the Part 4 regulations to the registered CPO of a commodity pool, whose shares the CPO intended to publicly offer and to list for trading on a national securities exchange. The relief was in the nature of substituted compliance with regulations. CFTC Letter No. 10-06.