On September 21st, the CFTC's Division of Clearing and Intermediary Oversight, in two separate letters, provided no-action relief to the general partner of a commodity pool from registering as a CPO under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliated, registered CPO 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 in connection with the operation of the pool. CFTC Letter No. 10-33; CFTC Letter No. 10-34.