Perfil
Ryan Hayden advises financial institutions, commodity market participants, financial service providers, and new market entrants on regulatory, compliance, and transactional matters involving derivatives. He counsels clients on the Commodity Exchange Act and the Dodd-Frank Act, including Title VII requirements, and regularly engages with U.S. financial regulators on registration, relief requests, enforcement and litigation matters. Ryan is regularly involved in registering exchanges and clearinghouses of the Commodity Futures Trading Commission (CFTC), including those involving prediction markets and digital assets.
Ryan’s practice is informed by his years as in-house counsel and as a chief compliance officer to CFTC registrants, and at the Commission itself. His comprehensive background and varied experiences give him a practical, business-oriented perspective that clients rely on when navigating complex regulatory frameworks, as well as insights into the policy decision-making of the Commission.
Ryan’s CFTC enforcement and litigation work has covered a wide array of registrants, market participants and individuals, including swap dealers, futures commission merchants, exchanges, and brokers. Allegations have covered the CFTC’s geographical and jurisdictional authority, as well as fraud, manipulation, trade reporting (swaps and futures), business conduct standards, trading documentation, recordkeeping, surveillance, compliance and supervisory programs, and other claims. Commensurate with enforcement proceedings, Ryan draws upon his experiences to help remediate compliance programs.
He also advises clients on compliant business structuring and strategy, particularly when launching new trading ventures or entering new asset classes, with recent focuses on binary options, event contracts, and perpetual contract offerings.
His advocacy efforts with the CFTC and SEC involve engaging with key points of contact on rulemaking processes, “right size” or “fit for purpose” relief initiatives, and regulatory accommodation for emerging market structures.
Before entering private practice, Ryan held senior in-house positions at two international commodity market participants and a global financial institution, where he provided derivatives, securities, and banking regulatory and transactional advice. He began his financial services career at the CFTC in Commissioner Bart Chilton’s office and at the U.S. Senate Banking Committee, grounding his practice in an understanding of how regulators and policymakers approach market oversight.
Ryan is an executive committee member of the Futures Industry Association’s (FIA’s) Law and Compliance Committee. Ryan also serves as Co-Chair to the DC Bar Corporation, Finance, and Securities Law Community’s Commodities and Derivatives Sub-Committee. He is a frequent speaker at industry conferences on topics including regulatory developments, compliance, market trends, and emerging issues in digital finance and prediction markets.
Concentrations
- Futures and derivatives
- Swap dealers and security-based swap dealers
- Designated contract markets, swap execution facilities, and derivatives clearing organizations
- Prediction markets and event contracts
- Financial services regulatory
- Commodity and derivatives litigation
Capacidades
Experiencia
- Majority Staff, U.S. Senate Committee on Banking, Housing and Urban Affairs, 2013
- Senior Lawyer, Cargill, Incorporated, 2021-2022
- Senior Legal Counsel/Chief Compliance Officer, E D & F Man Capital Markets, 2018-2021
- Legal Counsel, Vice President, Northern Trust Corporation, 2014-2018
Reconocimientos y Liderazgo
- Executive Committee Member, Futures Industry Association (FIA) Law and Compliance Committee
- Member, DC Bar
- Co-Chair, Derivatives Subcommittee, Corporation, Finance and Securities Law Community
Credenciales
- J.D., American University Washington College of Law
- B.S., cum laude, University of Mary Washington
- District of Columbia
- Illinois