The Commodity Futures Trading Commission’s Market Participants Division (MPD) reissued CFTC Staff Letter 25-50 to add an additional no-action position on how the relief in Letter 25-50 interacts with CFTC Staff Letter 14-126 for certain delegation arrangements between commodity pool operators (CPOs). Letter 25-50 provides no-action relief from certain CPO registration requirements for CPOs that are registered as investment advisers with the Securities and Exchange Commission and operate commodity pools that are privately offered solely to qualified eligible persons (QEPs). Under the reissued letter, MPD will not recommend that the Commission commence an enforcement action against a delegating CPO for failing to register as a CPO where all the criteria of Letter 14-126 are satisfied, except that the designated CPO is a QEP No-Action CPO rather than a CPO registered with the CFTC. The reissuance follows a request from the Managed Funds Association.
Commodity Futures Trading Commission 2026-02-26
Commodity Futures Trading Commission reissues Staff Letter 25-50 to expand no-action relief for commodity pool operator delegation arrangements
The Commodity Futures Trading Commission’s Market Participants Division reissued CFTC Staff Letter 25-50, adding a no-action position on delegation arrangements between commodity pool operators (CPOs). This reissuance clarifies that enforcement action will not be recommended against delegating CPOs meeting criteria of Letter 14-126, provided the designated CPO is a Qualified Eligible Person No-Action CPO. The update follows a request from the Managed Funds Association.