Tim Brown
Director
Mr. Brown advises clients on swap dealer and security-based swap dealer compliance projects addressing the relevant provisions of Title VII of the Dodd-Frank Act. His projects include the assessment, drafting, and revision of policies and procedures, assessing and implementing swap dealer and security-based swap dealer operational and compliance frameworks, reviewing and testing compliance-related control processes, and establishing governance structures to support an effective compliance program. Specific areas of review include business conduct standards, e-communication surveillance, trade, swap data reporting, capital, margin, risk, segregation, and additional Commodity Futures Trading Commission and National Futures Association (NFA) requirements.
He also works on compliance reviews and regulatory assessments for broker-dealers, swap dealers, and security-based swap dealers in the digital asset space, including interviewing firm personnel, enhancing policies and procedures, performing gap analyses against existing regulatory frameworks, and issuing recommendations for rule applicability and compliance program enhancement.
Mr. Brown was previously a manager at NFA. In this capacity, he led a team of examiners in completing examinations, investigations, and regulatory inquiries of registered swap dealers and futures commission merchants. He also created exam modules utilized by examiners, drafted internal guidance, and prepared and provided training to staff on new and amended regulatory requirements.
He received both his B.S. and M.S. in accounting from St. John’s University in New York.
- CFTC Enforcement Takes Aim at Position Limit Violations
- NFA Highlights Common Compliance Deficiencies for Swap Dealer Members
- CFTC Proposes Amendments to Reporting Requirements Including a 37% Increase in the Number of Reportable Fields
- Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023
- Firms Need to Weigh in on CFTC Notice of Proposed Rulemaking for Risk Management Requirements
