A common exemption from registration as a CPO is CFTC Rule 4.13(a)(3). CFTC Rule 4.13(a)(3) exempts from registration operators of privately offered commodity pools that limit their trading in commodity interest positions so that either (i) no more than 5% of the liquidation value of the commodity poolâ€s portfolio is used as a margin to establish such positions, or (ii) the aggregate net notional value of the commodity poolâ€s trading in such positions does not exceed 100% of the poolâ€s liquidation value.