CFTC Staff Letter 17-19: No-Action Relief from CPO Registration for University Entities

Division of Swap Dealer and Eileen T. Flaherty Intermediary Oversight Director U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-6700 Facsimile: (202) 418-5528 eflaherty@cftc.gov CFTC Letter No. 17-19 No-Action April 4, 2017 Division of Swap Dealer and Intermediary Oversight RE: Request for Relief from Commodity Pool Operator Registration for the University “A” Management Company and the Board of Directors of the “Z” Fund Dear:
This responds to your letter dated November 14, 2014, and ongoing and recent correspondence (the “Correspondence”), to the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”). In the Correspondence, you request no-action relief from commodity pool operator (“CPO”) registration required by Section 4m(1) of the Commodity Exchange Act (“CEA”) 1 on behalf of University “A” Management Company and the Board of Directors of the “Z” Fund (“‘Z’ Fund Directors”), with respect to several funds operated by them to manage the endowment and other assets belonging to the University “A” at Campus “B” (“Campus “B””), as well as other campuses of University “A” (“University”), their affiliates, and supporting organizations. 2