Dechert Comment Letter Regarding CFTC Proposed Rulemaking to Amend Regulation 4.5 and Related Issues

April 14, 2011

Dechert, on behalf of itself and a number of mutual funds and their investment advisers, authored a comment letter on the proposed rulemaking of the Commodity Futures Trading Commission (“CFTC”) regarding the modification of exclusionary relief and rescission of exemptive relief available to persons that would otherwise be required to register as commodity pool operators (“CPOs”). The letter addresses the proposed changes to CFTC Regulation 4.5, which currently excludes from the definition of CPO investment companies registered under the Investment Company Act of 1940, as amended, and addresses the proposed changes to CFTC Regulation 4.13(a)(4) as it applies to registered investment company wholly-owned offshore subsidiaries.

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