On December 7, the CFTC provided guidance to securitization vehicles on whether they may be excluded from the definition of commodity pool.  The CFTC will not recommend taking enforcement action against the operators of certain securitization vehicles that have not and will not issue new securities on or after October 12, 2012 for failure to register as a commodity pool operator, provided certain criteria are satisfied.  Also, for securitization vehicles that cannot claim relief either under this letter or CFTC Letter No. 12-14, which was issued on October 11, 2012, the CFTC will not recommend enforcement action against operators of securitization vehicles for failure to register as a commodity pool operator until March 31, 2013.  CFTC Release.  No-Action Letter.