Comment Text:
The Northern Trust Company ("Northern") is submitting the attached letter to request that the Commodity Futures Trading Commission (the "Commission") adopt an exclusion from the commodity "pool" definition, thereby excluding operators from commodity pool operator ("CPO") registration, and an exemption from commodity trading advisor ("CTA") registration for family offices (the "Family Office Exclusion"). Northern strongly supports the adoption of a Family Office Exclusion as soon as possible because the Commission recently adopted final rules that repeal the exemption from CPO registration under Rule 4.13(a)(4) and the accompanying exemption from CTA registration under Rule 4.14(a)(8)(i)(D).
