Five industry organizations requested that the Commodity Futures Trading Commission permit registered investment companies and privately offered investment funds to net uncleared swaps under limited circumstances to assess how they meet the so-called “net notional test” under applicable CFTC rules. The circumstances would be when (1) the termination dates and the reference asset or rate of the offsetting swaps are identical; and (2) the swaps to be netted are either with the same counterparty or with different counterparties but the offsetting swaps are both outstanding for no more than seven business days. Certain funds that trade futures in a de minimis manner apply the net notional test in order to be excluded from the definition of a commodity pool operator or to be exempt from CPO registration. Generally, under the test, the net aggregate net notional value of a fund’s commodity interest position cannot exceed 100% of the liquidation value of the fund’s portfolio after considering unrealized profits and losses. The industry groups that requested this relief are the Managed Funds Association, the Investment Company Institute, the Asset Management Group of the Securities Industry and Financial Markets Association, the Investment Adviser Association, and the Alternative Investment Management Association.