Douglas Harris

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+1 212 209 7454 direct
New York

Previous Experience

  • General Counsel, BrokerTec Futures Exchange LLC and BrokerTec Clearing Corp.
  • Partner, Regulatory Risk Services and Derivatives and Treasury Risk Management Groups, Arthur Andersen LLP
  • Consultant, Paloma Partners
  • Senior Deputy Comptroller for Capital Markets, Office of the Comptroller of the Currency
  • General Counsel, JPMorgan Futures Inc.
  • Assistant General Counsel, JPMorgan & Co. Inc.
  • Associate, Baer Marks & Upham

Thought Leadership

  • “In Defense of Derivatives and Structured Products,” co-authored with Eugene A. Ludwig, American Banker, Vol. CLXXV, No. 178, Nov. 18, 2010
  • “Financial Regulators Get Smart on Complex Structured Transactions,” Futures and Derivatives Law Report, Vol. 26, No. 9, October 2006
  • “Congress Establishes Legal Certainty for Bank Derivative Products,” Banking & Financial Services Policy Report, Vol. 20, No. 3, 2001
  • “Updated Commodity Law Was a Victory for Bank Regulators,” American Banker, Vol. CLXVI, No. 28, Feb. 9, 2001
  • Testimony before the U.S. Congress, Committee on Banking and Financial Services, on the Report of the President’s Working Group on Financial Markets on “Hedge Funds, Leverage and the Lessons of Long-Term Capital Management,” May 6, 1999
  • “Derivatives and the Recapitalization of Long-Term Capital Management — Issues of Credit Risk Management and the Appropriate Regulatory Response,” Derivatives Risk Management Service, March 1999
  • Testimony before the Committee on Banking and Financial Services of the U.S. Congress on H.R. 4062, “The Financial Derivatives Supervisory Improvement Act of 1998,” July 24, 1998
  • “CFTC’s OTC Concept Release Draws Ire of Working Group,” Futures & Derivatives Law Report, Vol. 18, No. 4, June 1998
  • Comment to “Derivatives Activities of Banking Institutions: Initiatives for Supervision and Enhanced Disclosure,” Current Issues Affecting Central Banks, Vol. 5, International Monetary Fund, April 1998

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Douglas Harris

Managing Director

Doug advises clients on regulatory matters involving risk management, compliance, investment products, derivatives, and capital markets. He also counsels financial services companies on general corporate governance, internal controls, and strategic advisory matters. He has considerable experience with the regulatory and compliance issues associated with trading, clearing, and capital markets activities, having served as senior deputy comptroller for capital markets at the Office of the Comptroller of the Currency, and as general counsel of a futures commission merchant and a designated-contract-market and derivatives clearing organization.


Immediately prior to joining Promontory, Doug was the general counsel and chief operating officer of BrokerTec Futures Exchange and BrokerTec Clearing Co. He has also served as senior deputy comptroller for capital markets at the Office of the Comptroller of the Currency, where he was responsible for the regulation and supervision of national bank capital markets activities, including trading, dealing, and investing in derivatives and emerging markets instruments, as well as the development of risk management policies and guidelines. Doug was the principal draftsperson of OCC Banking Circular 277, “Risk Management of Financial Derivatives,” the first bank regulatory guidance on managing the risks associated with derivatives, capital markets, and trading activities. He also served on the inter-agency task force on bank-related derivatives activities and as senior staff member of the president’s working group on financial markets. Prior to his time at the OCC, Doug served as assistant general counsel of JPMorgan and general counsel of JPMorgan Futures Inc.


  • J.D., Harvard Law School
  • A.B., cum laude, Harvard College

Affiliations, Awards, and Civic Engagements

  • Board director, National Futures Association; serves on the Executive Committee, Audit Committee, and Compliance and Risk Committee
  • Member, New York City Bar Association
  • Member, Structured Products and Derivatives Law Committee, New York State Bar Association
  • Member, Committee on the Regulation of Futures and Derivatives, American Bar Association
  • Member, Law & Compliance Division, Futures Industry Association
  • Member, Financial Markets Association
  • Former chairman, Career Gear
  • Charter member, Financial Markets Lawyers Group
  • Past member, Technology Advisory Committee, Commodity Futures Trading Commission

Representative Engagements

  • Reviewed the compliance, operational, and risk management control framework of a futures commission merchant/broker-dealer with global operations. The review came after an enforcement action issued by the Commodity Futures Trading Commission and regulatory concerns expressed by the Monetary Authority of Singapore and the U.K. Financial Services Authority.
  • Assisted a derivatives clearinghouse in establishing a compliance risk management program acceptable to the Board of Governors of the Federal Reserve System.
  • Provided expert advice to the CFTC on global best practices for the detection and prevention of fraudulent and manipulative trading activities.

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