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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
- 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
- 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.