Matthew B. Kulkin

Matthew Kulkin, co-chair of Steptoe's Financial Services Group, is a former Commodity Futures Trading Commission (CFTC) division director who advises financial market participants on a wide array of legislative, regulatory, compliance, and enforcement matters. Matt relies on his substantive knowledge and recent government experience to assist clients in navigating issues with the CFTC, the Securities and Exchange Commission (SEC), the Treasury Department, the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau (CFPB), and other regulatory agencies. Matt’s clients have included banks, broker-dealers, asset managers, proprietary firms, energy companies, trading venues, non-bank financial institutions, trade repositories, insurance companies, corporate end-users, financial market utilities, and systemically important financial institutions. 

Matt regularly provides CFTC, SEC, and NFA regulatory compliance counsel to swap dealers, security-based swap dealers, swap execution facilities, designated contract markets, futures commission merchants, broker-dealers, derivatives clearing organizations, clearing agencies, introducing brokers, investment advisers, and commodity pool operators. 

From 2017 through 2019, Matt served as director of the CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) under Chairman J. Christopher Giancarlo. At the CFTC, Matt was responsible for a number of significant measures related to financial markets, including futures, swaps, cryptocurrencies, and blockchain technology. 

Specifically, Matt oversaw policy-making and advised on enforcement matters related to swap dealers, futures commission merchants, commodity pool operators, commodity trading advisors, and the National Futures Association. His portfolio also included the Volcker Rule, substituted compliance determinations with non-US jurisdictions, planning for a no-deal Brexit, proprietary trading firms, and uncleared margin implementation. As the DSIO director, Matt worked closely with Executive Branch agencies, US and global independent regulatory bodies, and the US Congress. He also advised the CFTC's Division of Enforcement with respect to matters involving examinations and investigations of DSIO registrants. 

In private practice, Matt has also represented clients seeking access to capital under the legislation designed in response to economic crises: Consolidated Appropriations Act, 2021, the CARES Act (Payroll Support Program, Main Street Lending Program, national security business loan program), as well as similar programs under the Emergency Economic Stabilization Act of 2008. 

Previously, Matt served as co-chair of the DC Bar's Derivatives, Securitization, and Project Finance Committee. Matt is recognized as a thought leader on the Dodd-Frank Act implementation through his frequent writing and speaking engagements, including contributing to Derivatives Regulation – 2018 Cumulative Supplement (Wolters Kluwer) and co-authoring several chapters of the Emergency Economic Stabilization Act Handbook (Thomson Reuters).