Key takeaways:

• Following the enactment of the Dodd Frank Act, many more persons fell under the definition of Commodity Pool Operator (“CPO”) (with regard to commodity pools formed as limited partnerships, typically the general partner).
• The CFTC has seen a dramatic increase in requests to delegate CPO authority to another entity (for example, to ease administrative burdens investment managers are frequently named as a designated CPO where such investment manager sponsors a number of different pools that each use different general partners).
• The CFTC’s Staff Letter provides guidance and a Form Of Request intended to streamline and expedite the process by which CPOs request registration no-action relief and delegate CPO authority.