For the reasons set forth below, we will grant the request. Facts Based upon the representations made in your correspondence, we understand the facts to be as follows. U is a limited liability company which operates as a private investment fund. The members of U are V , A , his wife B and C , a long-time colleague and employee of A .
V is the managing member of U .
The partners of V are A and B , each holding a ten percent interest, and an irrevocable trust for the benefit of the three children, holding an eighty percent interest. A is the general partner of V . C is a special limited partner of V solely for the purpose of receiving a return on a particular investment that V has made with his assistance. V receives no compensation for acting as the managing member of U , and U is the only fund operated by V . A has been registered as a CPO since June of 1982 and he has more than thirty years experience in investment activities.