On August 18, 2026, the CFTC issued a Notice of Proposed Rulemaking inviting comments on proposed Regulation 4.13(a)(4) (Proposal), which, if adopted as written, will pare down CFTC registration requirements by offering an exemption to SEC-registered investment adviser (RIA) commodity pool operators (CPOs) whose investors are limited to qualified eligible persons. The Proposal also offers an exemption to certain commodity trading advisors from which those CPOs’ pools receive commodity interest trading advice. The Proposal comes on the heels of the CFTC staff’s December 2025 No-Action Letter No. 25‑50 (Letter 25‑50), which partly restored, on an interim basis, a CPO registration exemption that had been established in 2003 and then scuttled during the Dodd-Frank reforms of 2012. This article summarizes Letter 25‑50; breaks down the Proposal and explains its key differences from Letter 25‑50; examines how it will change RIA reporting if adopted as written; considers when deregistration is advisable in light of the Proposal; and offers practical takeaways. See our two-part series on Letter 25‑50: “CFTC No-Action Letter Restores Exemption for Many Asset Managers” (Mar. 12, 2026); and “Making Use of CFTC No-Action Relief” (Mar. 26, 2026).