XX seeks to avoid the cost and burden of providing duplicative information to participants.
Accordingly, XX is requesting exemption from the requirement that it distribute periodic account statements and distribute and file Annual Reports for Y and YY separately. Instead, XX is requesting that it be permitted to file periodic account statements on behalf of Y only, and file certified Annual Reports for Y only. Based upon the representations made in your correspondence and subsequent telephone call with Commission staff, we understand the relevant facts to be as follows. YY invests directly in commodity interests. The principal purpose of the financial reporting required by Rule 4.22 is to ensure that the pool participants receive accurate, fair and timely information on the overall trading performance and financial condition of the pool.