Any Board members actually trade OPM and are exempt from NFA/CFTC designations CTA and CPO? If so, what do your business entities look like? How many "qualified investors" do you have? I am asking, for I am considering applying for CPO exemption (CTA exemption is automatic is you advise fewer than 15 clients, and you do not call yourself a CTA). As I understand it, CPO exemption status requires the CPO to fit into a number of categories. The one that attracts me is the one that limits me to only accepting funds from "qualified investors." Therefore, suppose I create an LLC that acts as the exempt advisor, and I create another LLC that is the exempt CPO. Technically, the exempt CTA is only advising one client--the investment vehicle LLC. If that is true, then the investment vehicle can hold as many qualified investors as I want. Am I missing something or am I interpreting the regulations incorrectly? Appreciate feedback.
Follow the links on this page for a thorough education. http://www.cftc.gov/industryoversight/intermediaries/cpoctaexemptionsexclusions.html One of the clicky pokey things will take you to CFTC Regulations 4.13 and 4.14, which includes this delightful image: Another will take you to Regulation 4.7 which deals with QEP's.