MFA Requests CFTC for Interpretive Relief for § 4.13(a)(3) Exempt CPOs on a Registration Transition Period

On August 27, MFA submitted a request to the CFTC for interpretive relief for a commodity pool operator, exempt from registration under the CFTC’s § 4.13(a)(3) de minimis trading exemption, transitioning to full registration status.  MFA requests that the CFTC consider issuing interpretive guidance providing that a CPO that has filed an exemptive notice under § 4.13(a)(3) may continue to operate the fund, taking positions that exceed the de minimis level, provided that the operator submits a notice to the CFTC of its intention to register and uses its best efforts to become registered as a CPO as promptly as reasonably practicable.