CFTC’S DSIO Addresses the Treatment of Wholly-Owned Subsidiaries of Commodity Pools in No-Action Relief to Permit Consolidated Reporting

11 September 2014
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Key takeaways:

  • A recent CFTC no-action letter permits the registered CPO of a parent commodity pool to consolidate certain reporting obligations of the parent commodity pool with a wholly-owned trading subsidiary.
  • In the letter, CFTC staff confirms its position that a wholly-owned trading subsidiary that trades commodity interests is a separate pool that must independently satisfy exemption or exclusion requirements.