Key takeaways:

• CFTC interpretive relief excludes an entity holding the assets of general accounts of affiliated life insurance companies from the definition of “commodity pool” and confirms that the affiliated insurance companies that create such entities are not required to register as commodity pool operators (“CPOs”).
• CFTC permits registered CPOs to use any third-party recordkeeper, provided that all required books and records are maintained in accordance with CFTC regulations and timely produced upon request.
• CFTC allows CPOs that are registered with the CFTC but otherwise have no reporting obligations (such as CPOs operating only excluded or exempt pools) under Part 4 of the CFTC regulations to forego Form CPO-PQR filings.