The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on application of the de minimis trading tests in Regulation 4.5 and Regulation 4.13 to funds of funds.

SIFMA AMG believes that any formal CFTC guidance
regarding applicability of the amendments to rules 4.5 and 4.13 (CPO Amendments)
to operators of fund of funds should be principles based and consistent with “commercially
reasonable” standards for monitoring compliance.  To that end, SIFMA AMG
recommends certain principles to assist the CFTC in adopting the CPO Amendments
without imposing undue costs and burdens on funds, their managers, and fund
shareholders.