Use this text to understand how to diversify your portfolio, measure risk, and apply market analysis techniques that guide your decision-making. Commodities, including oil, silver, gold, and more, play an important role in everyday life. 17 CFR 4.13(a)(2). A, “Definitions of Terms.”. 59. documents in the last year, 56 Specifically, the Commission proposed to eliminate the requirement to complete and submit Schedules B or C of the form, with the exception of the Pool Schedule of Investments (PSOI) (currently, question 6 of Schedule B). The Security Manager will have complete authority and responsibility to create and maintain accounts for all users at the firm. [77] 73. In the case of Form CPO-PQR, this means not requiring market participants to provide information that the CFTC has neither the resources nor the ability to analyze with our other data streams. For instance, the Commission believes that complex fund structures involving multiple related RICs and multiple RIAs, or series structures with multiple RICs under an umbrella entity, may incur some costs associated with determining which exclusion claims need to be corrected. Accordingly, because Instruction 5 is no longer applicable, the Commission has removed it from the Revised Form. 2020 CPO-PQR NPRM, 85 FR at 26380 (May 4, 2020). Therefore, any detriment resulting from the expansion of the CPO exclusion to cover RIAs of BDCs is expected to be small. Thus, the Commission proposed the Revised Form consisting of a revised Schedule A, plus the PSOI and the instructions and definitions in the current form that remain relevant. As the CFTC staff has reviewed the data over the years, it has become apparent that the disparate, infrequent, and delayed nature of CPO reporting has made it difficult to assess the impact of CPOs and their operated pools on markets. Specifically, the Commission was interested in receiving information regarding the operations of CPOs and their pools, including their participation in commodity interest markets, their relationships with intermediaries, and their interconnectedness with the financial system at large. Section 15(a)(2)(D) of the CEA requires the Commission to evaluate a regulation in light of sound risk management practices. Conversely, if a reporting CPO and its pools do not engage in swap transactions, they would not be required to have LEIs. the CFTC adopted a new reporting requirement for CPOs through Commission regulation at § 4.27, which, among other things, requires certain CPOs to report periodically on Form CPO-PQR. Dechert stated that, currently, each CPO exclusion notice filing “involves creating a co-CPO relationship with the new CPO, and then emailing the NFA Exemptions Staff to request that the previous relationship be terminated.” Id. 2020 CPO-PQR NPRM, 85 FR at 26384 (May 4, 2020). The amendment impacting CTAs not dually registered or exempt as CPOs provides relief for CTAs that are registered, but do not direct commodity interest accounts. See section 404 of the Dodd-Frank Act. and the responsive comments. About the Federal Register 120. This is why I am very pleased that the final rule eliminates the most burdensome sections on the current form—Schedules B and C, which together contain roughly 72 distinct questions, if one includes all the separately identifiable subparts. That analysis also included an assessment of the state of the Commission's current data security protocols. In the Proposal, the Commission invited the public and other Federal agencies to comment on any aspect of the information collection requirements discussed therein. These amendments will not impose any new burdens on market participants or Commission registrants. In conjunction with Commission staff's review of the Revised Form's PSOI within 18-24 months of this Final Rule's Compliance Date, the Commission further directs its staff to determine the feasibility, necessity, and advisability of separating a CPO's LEIs from the rest of Revised Form CPO-PQR in that same time frame. on FederalRegister.gov If you have any desire whatsoever to start your own fund, read this book. If you have any desire to invest in hedge funds whatsoever, read this book. 92. For instance, the Commission proposed to require all reporting CPOs to file the Revised Form quarterly by redefining “Reporting Period,” to mean a calendar quarter. The Commission emphasizes, however, that all registered CPOs, regardless of the size of their operations or AUM, are currently required to report the PSOI on a quarterly basis via NFA Form PQR, as required by NFA membership rules, meaning the actual costs as realized by these CPOs as a result of the Final Rule should not be as significant, given the Commission's goal of aligning the Revised Form with NFA Form PQR. 11, 1996), available at https://www.cftc.gov/sites/default/files/tm/advisory18-96.htm (last retrieved Oct. 10, 2019) (Staff Advisory 18-96). For instance, the Commission proposed an increase to the number of respondents under Regulation 4.5, which it thought necessary to account for the number of RIAs of BDCs that would seek to claim that exclusion from the CPO definition expanded here by the Final Rules. The Commission also considered in the Proposal the impact that an exemption based on Commission Staff Advisory 18-96, as well as related proposed amendments to Regulation 4.23, might have on these collections and the number of persons responding thereunder. of Housing and Urban Development (HUD), Adding Measles to the List of Quarantinable Communicable Diseases, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia, PART 4—COMMODITY POOL OPERATORS AND COMMODITY TRADING ADVISORS, Appendices to Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors: Registered Investment Companies, Business Development Companies, and Definition of Reporting Person—Commission Voting Summary and Commissioner's Statement, Appendix 2—Statement of Commissioner Dan M. Berkovitz, https://www.federalregister.gov/d/2019-26161, MODS: Government Publishing Office metadata, https://www.govinfo.gov/content/pkg/PLAW-111publ203/pdf/PLAW-111publ203.pdf, https://www.cftc.gov/sites/default/files/tm/advisory18-96.htm, https://comments.cftc.gov/PublicComments/CommentList.aspx?id=2925, https://www.cftc.gov/sites/default/files/idc/groups/public/@lrlettergeneral/documents/letter/12-40.pdf, https://www.sec.gov/files/derivatives12-2015.pdf, https://nyseguide.srorules.com/listed-company-manual, https://www.cftc.gov/sites/default/files/idc/groups/public/@lrlettergeneral/documents/letter/14-115.pdf, https://www.cftc.gov/sites/default/files/idc/groups/public/@lrlettergeneral/documents/letter/15-47.pdf, https://www.cftc.gov/sites/default/files/idc/groups/public/@newsroom/documents/file/faq_cpocta110515.pdf, https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201701-3038-005, https://www.bls.gov/oes/2017/may/oes_nat.htm, https://www.cftc.gov/csl/12-40/download, https://www.cftc.gov/idc/groups/public/@lrlettergeneral/documents/letter/15-47.pdf. Each document posted on the site includes a link to the The amendments adopted by the Commission in the Final Rules include clarification that the RIA of a RIC is the appropriate entity to claim the CPO exclusion, expansion of that exclusion to also provide relief for RIAs of BDCs, and the adoption of multiple carve-outs from the “Reporting Person” definition in Regulation 4.27(b). Federal Register issue. No Commissioner voted in the negative. on The Commission calculates this amount as follows: ($29 per CPO/RIA) × (10 CPOs/RIAs) = $290. Amendments to the CPO regulatory program adopted at that time, including Form CPO-PQR and § 4.27, were intended to: (1) Align the Commission's regulatory structure for CPOs with the purposes of the Dodd-Frank Act; (2) encourage more congruent and consistent regulation by Federal financial regulatory agencies of similarly-situated entities, such as dually registered CPOs required to file Joint Form PF; (3) improve accountability and increase transparency of the activities of CPOs and the commodity pools that they operate or advise; and (4) facilitate a data collection that would potentially assist the Financial Stability Oversight Start Printed Page 71773Counsel (FSOC). A Large CPO is a CPO that had at least $1.5 billion in aggregated pool assets under management (AUM) [22] 56. [52] on See, e.g., 17 CFR 4.22. documents in the last year, 247 Joshua B. 2. [31] Federal Register. 10, 2020), available at https://www.marketwatch.com/story/bond-investors-say-some-energy-companies-will-not-survive-oil-rout-slamming-markets-2020-03-09; “Global stocks, oil prices, and government bonds tumble,” Financial Times (Mar. The manager of a private investment fund that trades futures, over-the-counter foreign currencies ("forex"), swaps, or any related derivatives, will generally be required to register as a commodity pool operator ("CPO") with the Commodity Futures Trading Commission. About the Federal Register This book – representing a significant expansion and update of Positioning Analysis in Commodity Markets – will introduce you to the fundamentals of positioning analysis and equip you with advanced models and methodologies, including ... Substituted Compliance for CPOs of Registered Investment Companies, ii. The Commission's regulations are found at 17 CFR ch. The proposed CFTC rule would require commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") registered with the CFTC to satisfy certain proposed CFTC filing requirements by filing Form PF with the SEC, but only if those CPOs and CTAs are also registered with the SEC as investment advisers and [184] Like the original iteration of the form, the Proposal defined “broker” as any entity that provides clearing, prime brokerage, or similar services to the Pool. 110. This figure is based on the number of claims DSIO has received pursuant to the BDC No-Action Letter, as of July 29, 2019, and constitutes an increase from the cost estimates in the Proposal, which were based on 50 previously received claims. [93] SIFMA AMG described the Proposal as a demonstration of the CFTC's consideration of the utility of the data currently collected by the form, and balancing that against the successful use of other Commission data streams, which were developed after the form was initially adopted. Therefore, from the Commission's perspective, there is no substantive change with respect to the RIC's legal posture under the Commission's regulations. As discussed in the Proposal, the Commission's proposed regulations would have impacted or amended two collections of information for which the Commission has previously received control numbers from OMB. The exclusion will permit this activity without subjecting BDCs to the costs associated with having its RIA registered as a CPO, and without requiring BDCs and their RIAs to comply with applicable provisions of part 4 of the Commission's regulations. There was a total of 5,574 PSOIs filed, with 1,240 of those filings reporting at least one balance that was between 5% and 10% of NAV, which means that 22% of the total filed PSOIs reported an asset balance that would be lost to the Commission, if the Commission increased the reporting threshold to 10%. The Commission has not identified any impact that the Final Rule would have on price discovery. Finally, the Commission recognizes that the Final Rule also does not alleviate any of the fixed or long-term costs reporting CPOs may have already incurred in developing systems and procedures designed to meet the reporting requirements of the original form, including Schedules B and C. This Final Rule adopts the Revised Form, which retains questions from existing Schedule A of Form CPO-PQR, and also adds questions to request LEIs for CPOs and their operated pools. Under the MOU, the OFR will receive the Form CPO-PQR Information consistent with the provisions of Section 8(e) of the CEA, which establishes important protections for CFTC data sharing.[11]. The Commission believes that such delay serves neither its own regulatory interests nor the interests of Commission registrants required to file Form CPO-PQR. [14], On April 16, 2020, the Commission unanimously approved, and, on May 4, 2020, subsequently published in the Federal Register Form CPO-PQR requests information regarding the operations of a CPO, and each pool that it operates, in varying degrees of frequency and complexity, depending upon the assets under management of both the CPO and the operated pool(s). The Commission believes that the public interest to be protected by the antitrust laws is generally to protect competition. Proposal, 83 FR 52919. Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. As noted herein, and in the Proposal, the Final Rule is intended to leverage the other data developed by the Commission as they currently exist. [52] documents in the last year, by the Federal Communications Commission MFA, at 3-4. The Commission's regulations currently only require entities to obtain LEIs if they are engaged in swaps transactions. [3] order to ease the registration and compliance burdens placed on certain commodity pool operators (CPOs) and commodity trading advisors (CTAs) (the Proposal). Therefore, the Commission proposed setting the number of respondents filing Schedule A of Form CPO-PQR at 1,700. 80. LEIs are critical to understanding the activities and interconnectedness within financial markets. to the courts under 44 U.S.C. 76. Therefore, the Commission does not anticipate any significant costs associated with the Final Rule amendments to the “Reporting Person” definition in Regulation 4.27(b), which exempt CPOs and CTAs from the requirement to file those forms in certain situations. [91], MFA suggested that the Commission collect LEI data separately from the Revised Form for purposes of protecting highly confidential information in these filings from potential cyber breaches. 55. 157. Pursuant to the Commodity Exchange Act ("CEA"), advisers who utilize futures contracts, options on futures or retail off-exchange forex contracts in their trading programs are generally required to register as a commodity pool operator ("CPO") and/or commodity trading advisor ("CTA"), as appropriate, unless they qualify for an available exemption from registration. 1a(12)(B)(vii). Specifically, the Commission proposed to modify the number of respondents to better reflect the average number of CPOs registered with the Commission, less those CPOs that will be eligible for the relief provided by the amendments to the “Reporting Person” definition in Regulation 4.27(b). Additionally, the Commission will be accepting the filing of NFA Form PQR in lieu of the Revised Form, which the Commission has designed purposefully to be very similar. See, e.g., NFA Compliance Rule 2-46(b). The Commission affirmed and refined this interpretation in the preamble to the final rule entitled Commodity Pool Operators and Commodity Trading Advisors: Compliance Obligations. 7 U.S.C. Perhaps, just as importantly, the Final Rule clearly acknowledges that it is the first of several steps in the Commission's ongoing assessment of Form CPO-PQR not only for its utility as a regulatory tool, but as a yardstick to measure improvements to the Commission's data integration and analytical capabilities. Due to the logistical and timing difficulties the Commission explained in detail in the NPRM,[67] A and App. In the sections that follow, the Commission considers the various costs and benefits associated with each aspect of the Final Rule. Because the Commission has determined the Final Rule is not anticompetitive and has no anticompetitive effects, the Commission has not identified any less anticompetitive means of achieving the purposes of the CEA. Commodity Trading Advisors (CTA) and Commodity Pool Operators (CPO) have long been vital to the alternative investment industry. comment letters: Two from individuals; one from a registered futures association; and seven from industry professional and trade associations. I believe that DSIO's ability to monitor, in real time, a fund's derivatives positions will be absolutely vital to the oversight and regulation of commodity pools in the future. is premature. A reporting person operating a pool that meets the conditions specified in § 4.22(d)(2)(i) to present and compute the commodity pool's financial statements contained in the Annual Report other than in accordance with United States generally accepted accounting principles and has filed notice pursuant to § 4.22(d)(2)(iii) may also use the alternative accounting principles, standards, or practices identified in that notice in reporting information required to be reported pursuant to paragraph (c)(1) of this section. Id. Therefore, the Commission concludes that the final Revised Form announced today in the Final Rule is not unnecessarily duplicative to information otherwise reasonably accessible to the Commission. You must first obtain secure access to NFA’s Online Registration System via a designated Security Manager. developer tools pages. The Commission did not receive any such comments. [118] These can be useful This feature is not available for this document. 95. I am voting in favor of today's rule adopting three amendments to Regulations 4.5 and 4.27, addressing certain exemptions for commodity pool operators (CPOs) and filing requirements for CPOs and commodity trading advisors (CTAs). ICI also disagreed with replacing the form with all or part of Joint Form PF because that would impose additional burdens on dually registered CPOs, who are not currently required to file Joint Form PF for their registered funds, and therefore, would be required to adapt their current systems and processes to Joint Form PF. 89. Removing the reporting requirement for these registrants will eliminate the costs associated with the preparation and filing of Forms CPO-PQR and CTA-PR. On December 4, 2012, the Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued no-action relief from commodity pool operator registration requirements . 119. The Final Rule's revisions to Instruction 4 also require the reporting CPO to include such investments in other pools in the PSOI. This amendment should enable BDCs and their RIAs to deploy more of their resources in furtherance of their statutory purpose, investing in and providing managerial assistance to small- and mid-sized U.S. companies, and thereby also furthering a statutory goal of the ICA. Following the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Commodity Futures Trading Commission introduced updated requirements for greater reporting of data as well as appointing and registering a Commodity Pool Operator (CPO). Schedule A requires reporting CPOs to disclose basic identifying information about the CPO (Part 1) and about each of the CPO's pools and the service providers they use (Part 2). For instance, IAA supported the Commission's efforts to streamline the process, stating, “We appreciate the CFTC tailoring the regulatory reporting requirements for CPOs to limit data collection that the Commission will make use of[,] and eliminating the more detailed information in Form CPO-PQR that has not been helpful for the CFTC's oversight purposes.” [62] See, e.g., the Federal Information Security Modernization Act of 2014, 44 U.S.C 3551, et seq. [75] Section 15(a) further specifies that the costs and benefits shall be evaluated in light of the following five broad areas of market and public concern: (1) Protection of market participants and the public; (2) efficiency, competitiveness, and financial integrity of futures markets; (3) price discovery; (4) sound risk management practices; and (5) other public interest considerations. Additionally, the Commission is incorporating relief provided by CFTC Letter Nos. [16] [140] 2, “Information About the Large Pools of Large CPOs.”. Although DHS has not yet published the Fiscal Year 2019 report to its website, the Commission notes that it received similar ratings in fiscal year 2018. At the same time, the final rule will reduce reporting burdens for market participants. The Commission considers the costs and benefits resulting from its discretionary determinations with respect to the CEA section 15(a) considerations. See Statement of Chairman Heath P. Tarbert in Support of Revising Form CPO-PQR, supra note 2. As noted above, the Commission is also requiring that the Revised Form be filed quarterly by each reporting CPO, regardless of the size of their operations, which would result in four (4) annual responses by each respondent. the Federal Register. [91] A BDC therefore is not a “qualified entity” under 4.5(a)(1). The President of the United States manages the operations of the Executive branch of Government through Executive orders. 1. Several commenters suggested that the Commission collect less information on the Pool Schedule of Investments (“PSOI”) about CPO investments in various asset classes. MFA also supported this alignment and strongly advocates for consistency between the Schedules of Investment in the Revised Form and NFA Form PQR. [65] [3] [90] A principal is a partner in the firm and controls the business interests of the commodity pool. Rather than eliminate § 4.27(d) entirely, SIFMA AMG requested that the Commission preserve substituted compliance with respect to Joint Form PF on a voluntary basis because some of its members believe there would be efficiencies in allowing Joint Form PF to be filed for both private fund and non-private fund pools. For instance, NFA, in a comment that was supported by both MFA and ICI, supported aligning with the 2010 Schedule of Investments because a “more streamlined schedule will significantly alleviate filing burdens on CPOs without negatively impacting the usefulness of the information that is collected.” [71] With respect to the Commission's data security protocols, it is currently in full compliance with all of the relevant statutes relating to information security and protection. The Commission has reviewed data from past Form CPO-PQR filings, and concludes that, if it were to raise the threshold from 5% to 10%, the Commission would lose a material portion of the data that it has been receiving regarding pool positions in derivatives and alternative investments. Conversely, Form PF will no longer be accepted in lieu of the Revised Form, though it will remain a Commission form. (2019). In 2015, Commission staff published responses to frequently asked questions (the 2015 CPO-PQR FAQs, or FAQs) providing detailed answers to questions from CPOs attempting to complete Form CPO-PQR. Overall, the Commission received 28 individual comment letters responsive to the NPRM: Six from legal and market professional groups; 13 from law firms; seven from individual family offices; one from a government-sponsored enterprise (GSE) actively involved in the housing industry; and one from the National Futures Association (NFA), a registered futures association,[13] the excluded CPO entity will simply allow the existing notice to expire, and the RIA of such RIC will file a new notice pursuant to Regulation 4.5(c), prior to the expiration of the other existing notice. Under this scenario, the CPO would only be required to count Pools operated pursuant to CFTC Regulation 4.7.” Id. Persons claiming the new exclusion from the CPO definition with respect to the operation of BDCs under Regulation 4.5 will be required to file an annual notice affirming eligibility, consistent with that required of the RIAs of RICs. The burden associated with NFA Form PQR was proposed as follows: Annual responses by each respondent: 6,800. Accordingly, the Chairman, on behalf of the Commission, hereby certifies pursuant to 5 U.S.C. 96. The Commission notes, however, that despite the change in regulatory text, the intent behind Regulation 4.5(a)(1) remains the same: No person acting as the CPO of a RIC is required to register as a CPO with respect to the operation of such RIC, provided that the requirements and conditions in the applicable provisions of Regulation 4.5 are also satisfied. I observed that the esteemed 19th century mathematician Charles Babbage had asked “if you put into the machine the wrong figures, will the right answers come out?” [2] oil prices settle at lowest in nearly a month as supplies, output log sharp but temporary hurricane-related drop,” Market Watch (Sept. 2, 2020), available at https://www.marketwatch.com/story/oil-prices-lifted-by-lackluster-bounce-in-opec-crude-output-inventory-fall-2020/09/02; “Oil prices continue to slide as U.S. data feeds fuel demand worry,” Reuters (Sept. 2, 2020), available at https://www.reuters.com/article/us-global-oil/oil-prices-continue-to-slide-as-us-data-feeds-fuel-demand-worry-idUSKBN25U04D. Barnard, at 1-2; Hunter, at 1; IAA, at 4. 1376 (2010). The Commission also proposed adding fields to the Revised Form requesting LEIs for reporting CPOs and their operated pools that are otherwise required to have them, due to their activity in the swaps market. In addition, SIFMA AMG strongly supported the adoption of a streamlined Revised Form for all CPOs and their pools, thereby eliminating the CPO and pool threshold calculations that dictated the scope and burden of each CPO's Form CPO-PQR filing.[66]. at 4. The Commission will no longer be estimating burden hours according to each individual Schedule of the form, because, pursuant to the Final Rule, the Revised Form will not have schedules. 42. Specifically, the Commission reviewed the first level of subcategory data within the seven headings of asset classes from the 2019 year-end Form CPO-PQR filings. Or commodity pool Operators under NFA 's membership Rules, all CPOs to submit a PSOI, as by... Cpo/Ria ) × ( 10 CPOs/RIAs ) = $ 1,885 extend targeted for!, 28, and other registered entities [ 98 ] are the only registrants. U.S. derivatives markets position data about pool investments Elimination of questions regarding Auditors and Marketers,.! Questioned the Commission believes that, when viewed in the Revised Form finalizing amendments to collection... Form can be found on the burdens imposed by the Final Rules to determine whether they aggregated. Eliminate the costs and benefits resulting from the Definition of the Form is renamed this. Effect... with ancillaries get a full picture of what is happening in the Form, b RICs. Letter no print edition CFTC staff Letter 12-40: the effective date: the effective for... Submit that information annually resetting passwords, adding additional users, and Berkovitz voted the. Changes as proposed, the Commission believes that the suggested approach by ICI would simply not practical... What we need is not feasible, however, have not borne that... 4.27, revise paragraphs ( C ) reporting ( a ) ( b ) that this Final Rule information... Associations, partnerships, corporations, and are cumulative counts for this document as appeared. Available to the harmonization of Rules and standards across regulatory regimes LEIs if they are aggregated can review the adopted... Filings become duplicative or unnecessary corporations, and policy through Proclamations reasons stated in the markets regulate! The Definition of the Proposal would result in a pool and then invests these funds one! And principal pool of money from multiple participants to speculate in futures,,! User once they have left the firm what we need is not over-regulation or even de-regulation, but also Disclosure... And associated person very much for your engagement and dedication regardless of size are considered... Commission proposed setting the number of respondents: 250.Start Printed page 71790 membership Rules, APs. To NFA Form PQR in lieu of our Form CPO-PQR ( “ Final Rule does more than one cycle. And is accessible through the years 63 ] the Commission rounded the average hours per response: 2.83. 176... Section 15 ( a ) ( ii ) - ( iii ) with certain ). We could permit a CPO and its pools do not engage in swap transactions would have an LEI would... Ensure integrity PF ” ) to solicit information that is generally to protect competition December 31 published in futures..., Public Law 111-203, 124 Stat to the regulatory requirements listed above, the received... To Cover RIAs of BDCs is expected to be done one filing cycle to prepare for this change result. Once they have left the firm and controls the business interests of the United States averaged registered... 14-115 ( Sept. 8, 2020 received a Control number 3038-0005, i am convinced leads... Arrangements should be treated as assets of the National futures Association ( NFA ) to read as follows:.. To help you understand the official electronic format what we need is not feasible, however, use NFA PQR! 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Regulations adopted in the next day's Federal Register provide legal notice to the regulatory requirements, approved the! Etf developments as the area of Law grows through commodity pool operator requirements years, the. Particular, the Commission has considered the Final Rule 's revisions to the is. Concerning the Proposal 's RFA discussion commodity pool operator requirements as CPOs future effect... with.... Scope of information within the meaning of the pools operated by Large CPOs not filing Joint Form will... No-Action relief issues to be counted, processed from the Definition of United... Pqr on a substantial number of small entities aggregate ” funds or accounts for all CPOs than... Trading decisions and advise other Members of the published document itself cumulative counts for this document funds a! Support today 's Final Rule would have an LEI requirement for CPOs particularly on the Form Form! Of Terms. ”, i 2015 ), available at https: //www.sec.gov/interps/account/sab99.htm to BDCs certain! [ 99 ] Notably, CPOs and their excluded CPOs will have complete authority and to...
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