The Commodity Futures Trading Commission’s Division of Clearing and Intermediary Oversight (DCIO) issued two substantively identical no-action letters, allowing the investment manager of a commodity pool to serve as the registered commodity pool operator (CPO) in lieu of the pool’s general partner. DCIO conditioned relief on the following facts: (i) the manager was registered as a CPO; (ii) the manager and the general partner were affiliates under common ownership and control; (iii) the general partner represented that it would not solicit investors, manage any property of the pool or undertake any other activities subject to CFTC regulation; and (iv) the manager and the general partner each acknowledged joint and several liability for the other’s commodities laws violations.

 http://www.cftc.gov/stellent/groups/public/@documents07/documents/letter/07-18.pdf

 http://www.cftc.gov/stellent/groups/public/@documents07/documents/letter/07-19.pdf