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Jeffry M. Henderson focuses his practice on a wide variety of compliance, regulatory, litigation and managed fund matters. In the areas of futures, derivatives, forex and securities issues, he advises a broad range of clients: broker-dealers, investment advisers, introducing brokers, futures commission merchants, forex dealer members, commodity pool operators, commodity trading advisors and hedge fund managers. Jeffry also counsels proprietary trading firms and exempt investment managers regarding disclosure, regulatory and enforcement matters. He is also routinely involved in regulatory work and defending member firms before the SEC, CFTC, NFA and FINRA.

His industry experience began on the floor at Chicago Board of Trade and subsequently as general counsel for a publicly-traded futures commission merchant.

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?

In a recent public speech, CFTC Chairman Timothy Massad described cybersecurity as “perhaps the single most important new risk to market integrity and financial stability.”  On March 18, 2015, CFTC staff conducted a roundtable regarding this topic, during which CFTC suggested possible proposed rulemaking.  CFTC staff said that CFTC is considering a rule imposing cybersecurity requirements on exchanges and clearing organizations, but one that at least initially would not apply to other market participants.  Chairman Massad indicated that a proposed rule would focus on setting standards for testing: (a) system safeguards; (b) vulnerability and penetration; (c) key controls; and (d) business recovery and disaster recovery. 
Continue Reading Cybersecurity Viewed as Market Risk by CFTC