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    Many thanks to Ira, Jay, John Cappello, Bill S. and thanks to Richard
Chehovin who suggested that I call the National Futures Association in
Chicago. and this is the information also for Bill W.  I intend to call them
today to confirm what I learned from the web site of the Commodity Futures
Trading Commission, last evening:
www.cftc.gov/
      Once there, go to search and search for Commodity Pool Operator or
Rule 4.13.  (I had trouble with the NFA site so choose the CFTC site).
    Everyone was correct regarding the 15 or less participants and $200,000
or less in initial capital.  Also, and most important, if you want to
operate as a Commodity Pool Operator without registering, you can
participate in the profits but you can not operate another pool.  This was a
big question as everyone I asked told me that I would not be able to share
in the profits (hopefully there will be something to share), unless I was
registered as a CTA and took the exam, etc.
    There are other requirements and at one point they seem to contradict
the "one pool at one time" scenario.  However, this is where you can find
the material.
    That's it and thanks.  I'll let you know what they have to say in my
phone conversation today if there are any great discrepancies.

Regards,
 John,

jdfo@xxxxxxxxx