CFTC Staff Letter 90-4 DEA (No-Action): Mint Investment Management and Northfield Trading Position Limits

DIVISION OF
ECONOMIC ANALYSIS
COMMODITY FUTURES TRADING COMMISSION 2033 K STREET, N.W., WASHINGTON, D.C. 20581 (202) 254-6265 FACSIMILE July 24, 1990 Re: Request for No Action Regarding Speculative Position Limits Dear :
By letter dated June 29, 1990, you requested the Division's views with regard to the application of speculative position limits to the positions of and Letter from to Paul M. Architzel, Division of Economic Analysis, dated June 29, 1990 (June 29 letter). That correspondence included a cover letter, an affidavit of on behalf of , an internal memorandum to all and , employees, an affidavit of on behalf of , an internal memorandum to all employees from , and Disclosure Documents for both and These were supplemented with two additional letters dated July 12 and 13, 1990. From this correspondence, we understand the facts to be as follows. is a registered commodity trading advisor (CTA). , as a limited partner, has joined with , as the general partner, to form , also a registered CTA. is predominantly owned by and has no ownership interest in will be owned 90 percent by will manage both customer and proprietary ac￾counts, using a technical trading system. This trading system was developed through the joint research of and beginning in 1985 and prior to "any involvement with the principals of " Moreover, technical trading system operates independently from trading is long-term and trend-following in nature, with only three to four transactions per year per market on average, and all trading decisions are made basis market closes for action to be taken the next day. The system, in contrast, is short-term in orientation, with trades initiated basis intra-day market. action and may have positions with or against the prevailing long-term trend. June 29 letter, at page 2.