If you collect other people's money into a single fund and trade futures with it, you are running a commodity pool and are presumptively a CPO. The operator must deliver a disclosure document, send periodic account statements and an annual audited report to participants, and keep the pool's assets separate from its own.
The role often sits alongside a commodity-trading-advisor registration, because the same firm both operates the fund and directs its trading.
Common exemptions cover pools sold only to sophisticated investors with limited futures exposure, but they must be claimed by filing a notice, and they are lost if the pool exceeds the trading thresholds. Running a pool without registration or a valid exemption is a straightforward enforcement case.
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