I agree with what you are saying here. I think we are on the same ground. What I am interpretting here is that if you go above the $400,000 amount, have more than 15 participants or operate more than one pool at a time, then your Exemption would not be valid and you would have to register as a CPO
In life I have three types of relationships, Friends, Acquaintances, & Tolerations. Try not to get in the third group.