Jonathan Flynn focuses his practice on commodities, securities, derivatives and related regulatory and litigation matters. He represents a wide range of participants in the physical commodity and financial markets, including investment banks, major commodity merchants and trading houses, hedge funds and other asset managers, market intermediaries, and industry trade associations, on a broad range of regulatory issues involving the Commodity Futures Trading Commission (CFTC), the National Futures Association (NFA), the Securities and Exchange Commission (SEC), and the Federal Trade Commission (FTC). Jon also represents companies and individuals in government investigations by the government regulators and the US Department of Justice related to manipulation, fraud, price reporting and commodity indexes, supervisory controls, position limits and other prohibited trade practices.
Jon has extensive experience with administrative rulemaking and the legislative process. He lobbied successfully on behalf of industry trade associations and individual market participants for amendments to the Dodd-Frank Act prior to enactment. He continues to represent clients in agency rulemakings, and counsels clients regularly on compliance and implementation issues related to new CFTC and SEC regulations.
Prior to returning to private practice, in 2012 and 2013, Jon served as a policy advisor on derivatives at the SEC. During this time, he represented SEC staff in various international working groups, including IOSCO’s Task Force on OTC Derivatives and the Financial Stability Board’s OTC Derivatives Working Group, and coordinated with other US financial regulators, including the CFTC, Treasury, Federal Reserve Board, and Federal Reserve Bank of New York on policy issues related to implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Jon also worked extensively on the SEC’s proposed rule on cross-border security-based swap activities and international efforts to develop a harmonised approach to the cross-border regulation of derivatives.