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Jeffry M. Henderson

Jeffry M. Henderson, a former general counsel for a publicly traded futures commission merchant, has deep futures and derivatives industry experience. He focuses his practice on a variety of complex compliance, regulatory, investigation, litigation, and managed fund matters. This representation regularly involves futures, derivatives, swaps, forex, securities, cryptocurrency, and binary options. He represents and advises a broad range of clients, including futures commission merchants, broker-dealers, investment advisers, commodity trading advisers, introducing brokers, forex trading firms, commodity pool operators, and hedge fund managers. He also provides counsel to a variety of industry participants, including proprietary trading firms and exempt investment managers regarding disclosure matters and compliance obligations and regulatory and enforcement matters. He is also regularly involved in defending member and member firms before CFTC, NFA, SEC and FINRA. He currently serves as a public director for an applicant Designated Contract Market and an applicant Designated Clearing Organization.

CFTC DoE Director David Miller highlighted prediction markets and crypto assets as perhaps the two most dynamic markets in finance during his March 2026 remarks at NYU Law School. 

Continue Reading Prediction Markets: A CFTC Enforcement Update

Prediction markets are electronic trading platforms where participants buy and sell interests in future event outcomes, from elections to economic indicators. Prices reflect aggregate probability, with event contracts typically offering binary yes or no outcomes.

Continue Reading CFTC Regulatory Developments on Prediction Markets and Event Contracts

On Feb. 25, the CFTC’s Division of Enforcement released an advisory highlighting the benefits of self-reporting, cooperation, and remediation for violations of the Commodities Exchange Act. It refines the Division’s approach, guiding how these factors influence enforcement recommendations.

Continue Reading CFTC Issues Enforcement Advisory on Benefits of Self-Reporting, Cooperation, and Remediation

On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the

Continue Reading CFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’


Continue Reading Commodity Futures Trading Commission Issues Time-Limited Relief from CFTC Rule 1.56


Continue Reading CFTC Proposes Expanding Exemption for Non-U.S. Commodity Pool Operators

On March 21, 2019, in Whitaker v. Wedbush Securities, an Illinois appellate court for the first time addressed the liability of a futures commission merchant (FCM) or broker-dealer (BD)
Continue Reading When Can Futures Commission Merchants and Broker-Dealers Be Deemed Banks?