All Letters

86-07 ; Section 4m(1); No-Action
The Division of Trading and Markets granted CPO registration no-action relief to the one member of a foreign fund’s board of directors who was a U.S. citizen. (T&M)

86-08 ; Regulation 4.5; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to a trust comprised of multiple-employer pension plans, each of which would be a “qualifying entity” under Regulation 4.5(b). (T&M)

86-11 ; Sections 4m(1); No-Action
The Division of Trading and Markets issued CPO registration no-action relief to the operator of a partnership which, among other things, only traded commodity futures contracts in a manner incidental to its securities trading. (T&M)

86-12 ; Section 4k(2); No-Action; Exemption
The Division of Trading and Markets granted CPO registration no-action relief to certain employees of a bank which were not involved in managing investment funds. (T&M)

86-05 ; Section 4(a); No-Action
The Office of General Counsel granted no-action relief to permit an export trading company that was a subsidiary of a bank holding company to solicit or accept orders for any commodity futures transaction conducted off a designated contract market, provided the Federal Reserve concurs that these activities are permissible under the Bank Holding Act and the export company does not offer these services to the general public.

86-13 ; Regulation 4.31; No-Action
The Division of Trading and Markets granted disclosure no-action relief to two CTAs offering advice exclusively to registered investment companies which had filed a Notice of Eligibility under Regulation 4.5. (T&M)

86-19 ; Section 4m(1); No-Action
The Division of Trading and Markets granted CPO registration no-action relief to the operator of a limited partnership composed of related limited partners which was adding a general partner. Division staff outlined the reasons and conditions of this position, including the close nature of the limited partners and the limitations on the general partner’s activities. (T&M)

86-24 ; Section 4m(1); No-Action
Interpretation and No-Action; The Division of Trading and Markets issued an interpretive letter stating that stating that certain insurance company activities were “solely incidental” to a company’s business and therefore would not place the company within the definition of a CTA. Although Division staff did require certain actions to be taken by the company, it granted CTA registration no-action relief in consideration of a House of Representatives Committee on Agriculture Report responding to a proposal to exclude certain activities of the insurance industry from the CTA definition. (T&M)

86-31 ; Section 4m(1); No-Action
The Division of Trading and Markets granted CTA registration no-action relief to a bank, provided certain conditions were met. (T&M)

86-30 ; Section 4m(1); No-Action
The Division of Trading and Markets issued CPO registration no-action relief to the general partner of a limited partnership, where the general partner had limited responsibility and authority over the partnership’s commodity interest trading activity. (T&M)