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Stephen Humenik
Stephen M. Humenik
Of Counsel
Washington +1 202 662 5803 shumenik@cov.com Download V-card

Stephen M. Humenik leads the firm’s futures and derivatives practice. He has extensive experience on cross-border regulatory, compliance and enforcement matters involving the U.S. Commodity Futures Trading Commission (CFTC) and markets for derivatives and physical and financial commodities. Mr. Humenik applies his business, operational, and government experience to the implementation of CFTC regulations, including the registration, trading, clearing and other compliance obligations of the Dodd-Frank Act and other global regulatory reforms.

  • Representation of ISDA on an analysis of the implications of Brexit on U.S. derivatives market participants, including on the CFTC's cross-border and substituted compliance regime. 
  • Advise Tullett Prebon on its initial registration with the CFTC as a non-U.S. swap dealer, including advice on the CFTC’s cross-border guidance and substituted compliance determinations. 
  • Advise Coinbase, Inc. on financial services regulations, including the regulatory requirements of the CFTC related to cryptocurrency. 
  • Advise multiple swap dealers on compliance with the CFTC’s regulations, including rules related to external business conduct standards and the trading of swaps on SEFs. 
  • Representation of ISDA on a white paper related to a principles-based approach to the CFTC's cross-border and substituted compliance regime. 
  • Advise multiple derivatives trading platforms on the application of the CFTC’s core principles for swap execution facilities (SEFs) and designated contract markets (DCMs), including the regulatory implications of business requirements and operational and technology functions and the clearing services provided by the CFTC-registered clearing house (DCO).
  • Prepare comment letter for a trade association submission to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) related to the Principles of Financial Market Infrastructures (PFMIs) that relate to central counterparties (CCPs).   
  • Advise multiple derivatives market participants, including financial institutions on compliance with CFTC regulations, including policies and procedures related to futures and swaps trading and clearing. 
  • Advise a U.S. investment bank with international offices on the regulatory treatment of derivatives, including the CFTC’s cross-border guidance. 
  • Advise multiple derivatives market participants regarding the regulatory requirements for domestic and international derivatives activities, including swap product analysis and swap dealer registration requirements.
  • Conduct real-time reviews of futures and swaps trading activity to verify compliance with internal policies and CFTC regulations, including position limits and other CFTC reporting.
  • Prepare comment letters on behalf of trade associations related to a Joint Audit Committee policy on margining of accounts held by the same beneficial owner as well as the impact of the Basel III leverage ratio on segregated margin.
  • Prepare comment letters on behalf of a leading SEF related to the CFTC’s cybersecurity proposed rules and the swap data standards.
  • Prepare a comment letter on behalf of a proprietary trading firm related to the CFTC’s proposed regulation of algorithmic trading.
  • Represent several individuals in exchange and CFTC enforcement matters related to trade practice violations, failure to supervise, and market manipulation.

Memberships and Affiliations

  • District of Columbia Bar Association
  • Chicago Bar Association, Futures and Derivatives Law Committee

Previous Experience

  • Eris Exchange LLC, General Counsel and Chief Regulatory Officer (August 2010-April 2013)
  • U.S. Commodity Futures Trading Commission, Technology Advisory Committee, Industry Member (June 2012- April 2013)
  • U.S. Commodity Futures Trading Commission, Special Counsel and Policy Advisor to Commissioner Scott O’Malia (November 2009-August 2010)
  • U.S. Commodity Futures Trading Commission, Senior Trial Attorney, Division of Enforcement (May 2007-November 2009; August 1999-October 2003)
  • Legal 500 US, Energy: Regulatory