The Commodity Exchange Act defines a CPO as any person:
Engaged in a business that is:
of the nature of a commodity pool, investment trust, syndicate, or similar form of enterprise;
who solicits, accepts, or receives from others, funds, securities, or property, either directly or through capital contributions;
the sale of stock or other forms of securities, or otherwise, for the purpose of trading in commodity interests, or
Who is registered with the CFTC as a commodity pool operator.