My Work

How I can Help You:
Regulatory Strategy & Compliance
With nearly two decades of experience at the Commodity Futures Trading Commission (CFTC), I provide strategic legal counsel to financial firms on navigating the complex landscape of U.S. financial regulations. My deep institutional knowledge helps you not only comply with the rules but also build a resilient and defensible business strategy.
I can help you with:
Developing and enhancing comprehensive compliance programs.
Providing day-to-day legal counsel for financial intermediaries (FCMs, CTAs, CPOs, etc.). Offering guidance on Dodd-Frank rules and external business conduct standards.
Reviewing Chief Compliance Officer annual reports and enhancing risk management protocols.
Regulatory Examinations & Enforcement Support
Facing a regulatory examination from the NFA, SEC, FINRA, or Treasury can be a daunting process. I leverage my experience as the primary interface for these inquiries at the CFTC to guide you through the process, manage complex scrutiny, and ensure a strategic, effective response.
My services include:
Conducting pre-examination readiness assessments to prepare your team.
Providing strategic guidance and representation during regulatory examinations.
Managing responses to inquiries and potential enforcement actions.
Analyzing enforcement actions and advising on civil litigation or mediation strategies.
Fintech & Digital Asset Advisory
The digital asset space is evolving rapidly, with new regulations and legal challenges emerging constantly. As a veteran of the CFTC’s Financial Innovation Working Group, I offer specialized guidance on the legal and regulatory issues impacting cryptocurrency, blockchain technology, and other emerging financial products. I help you understand the risks and build a compliant foundation for your innovative offerings.
I specialize in:
Conducting legal and regulatory risk assessments for new fintech products.
Providing guidance on cryptocurrency and digital asset regulations.
Developing and issuing complex no-action and interpretive letter requests.
Advising on emerging issues to build a forward-thinking compliance program.
General Corporate & Securities Law
Beyond regulatory matters, a strong corporate foundation is essential for business growth. My experience includes drafting and reviewing critical corporate and securities documents, ensuring your business is structured to scale and attract investment.
I can assist you with:
Drafting and reviewing securities filings (Forms S-1, 10-K, etc.).
Handling legal documents for mergers and acquisitions.
Providing guidance on corporate governance and compliance.
Negotiating and drafting a wide range of contracts.
Final Rules CFTC
Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties (2012)
Foreign Futures and Options Transactions (Tokyo Grain Exchange Part 30) (2008)
Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries (2010)
Advertising by Commodity Pool Operators, Commodity Trading Advisors, and the Principals Thereof (Feb 2007)
Delegation of Authority to Director of the Division of Clearing and Intermediary Oversight; Correction (Jan 2005)
CFTC ORDER: Eligible Contract Participant Definintion and Single Asset Development Borrowers (Mar 2003)
Proposed Rules
Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties (2010)
Regulation of Off-Exchange Retail Foreign Exchange Transactions and Intermediaries (Jan 2010)
Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors (2018)
Agency Information Collection Activities Under OMB Review (2023)
Agency Information Collection Activities: Notice of Intent To Extend Collection 3038-0005: Rules Relating to the Operations and Activities of Commodity Pool Operators and Commodity Trading Advisors and to Monthly Reporting by Futures Commission Merchants (July 2023)
Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors Oct 2018)
Advertising by Commodity Pool Operators, Commodity Trading Advisors, and the Principals Thereof (Aug 2006)
Interpretive Letters (selected)
Exemption allowing Two Sigma to Treat Certain Employees as Qualified Eligible Persons for CFTC Letter 24-05
Exemptive Relief from Audited Financial Statements for a CPO (stub relief) 4.7(b)(3) and 4.22 Letter 24-04 (2024)
Exemptive relief regarding quarterly account statements for a CPO (4.7(b)(3)) Staff Letter 23-04 (2023)
Royalty Pharma No-Action Relief from Registering as a CPO or CTA CFTC Letter 21-06 (2021)
Exemptive relief from Quarterly Account Statements 4.7(b)(2) CFTC Staff Letter 19-03 (2019)
Exemptive relief from Quarterly Account Statements 4.7(b)(2) CFTC Staff Letter 18-34 (2018)
Exemptive relief from Audited Financial Statements under 4.7(b)(3) and 4.22 Staff Letter 17-20 (2017)
Staff Interpretation Regarding Separate Compensation and CTA Registration Requirements Under MiFID II (CFTC Letter 17-65, 2017)
No Action Letter 09-03 Re:General Partner of a pool delegation of duties to a registered CPO (2009)
Staff Interpretation Letter 04-15 Re: Definition of Introducing Broker and Software Provider allowing direct access to FCMs (2004)