Overview
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.
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.
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).
- District of Columbia
- Georgia
- J.D., The George Washington University Law School, 2005
- B.A., Tufts University, 2002
Representative Matters
- Provide CFTC, SEC, NFA regulatory compliance counsel to swap dealers, swap execution facilities, designated contract markets, derivatives clearing organizations, futures commission merchants, and commodity pool operators.
- Develop a comprehensive compliance and remediation plan for a registered swap dealer in connection with a CFTC investigation and enforcement matter.
- Act as regulatory policy counsel for a global financial services trade association – preparing comment letters, developing industry best practices, and engaging with policymakers.
- Prepare new swap, futures, and options product listing submissions, as well as amendments to rulebooks and associated policies and procedures.
- Pursue no-action relief for futures commission merchant with respect to certain CFTC regulations.
- Advise on digital currency options in connection with acquisition of designated contract market and derivatives clearing organization.
- Assisted air carrier contractor to receive US federal funding under the CARES Act Payroll Support Program.
News & Publications
Press Releases
Steptoe Launches Financial Services University
October 21, 2020
Media Mentions
Federal News Network Interviews Matt Kulkin on Writing Effective Public Comments
September 21, 2020
Media Mentions
American Banker Quotes Matt Kulkin on Small Banks, Main Street Lending Program
August 19, 2020
Publications
Bloomberg Tax
June 22, 2020
By: Matthew B. Kulkin, Josh Oppenheimer, Anna M. Stressenger
Client Alerts
Understanding the Main Street Lending Program
June 16, 2020
By: Matthew B. Kulkin, Micah S. Green, John T. Collins, Scott A. Sinder, James D. Barnette, Luis G. Fortuño, Jason Abel, George Callas, Kate Jensen, Josh Oppenheimer, Anna M. Stressenger
Resources
Financial Services Group Advisory
Key Takeaways: CFTC Issues No-Action Relief for FCM Treatment of Separate Accounts Under Rule 1.56
September 16, 2020
By: Matthew B. Kulkin, Stacie R. Hartman, Charles R. Mills, Micah S. Green, Richard Shilts, Michael V. Dunn, Josh Oppenheimer
Exempt Organizations Advisory
Federal Reserve Releases FAQs for Nonprofit Main Street Lending Program
July 23, 2020
By: Suzanne Ross McDowell, Elinor Ramey, Matthew B. Kulkin, Josh Oppenheimer, Anna M. Stressenger, Catherine Wilkinson
Exempt Organizations Advisory
Main Street Lending Program Finalizes Expansion to Nonprofits
July 17, 2020
By: Matthew B. Kulkin, Elinor Ramey, Josh Oppenheimer, Anna M. Stressenger
Exempt Organizations Advisory
Main Street Lending Program Expanding to Nonprofits
June 16, 2020
By: Matthew B. Kulkin, Elinor Ramey, Josh Oppenheimer, Anna M. Stressenger
Financial Services Group Advisory
How to Access Treasury Department Funding Under the CARES Act
March 29, 2020
By: Matthew B. Kulkin, Micah S. Green, John T. Collins, Scott A. Sinder, James D. Barnette, Luis G. Fortuño, Jason Abel, George Callas, Kate Jensen, Josh Oppenheimer, Anna M. Stressenger
Financial Services Group Advisory
Federal Reserve Establishes, Expands Emergency Capital Liquidity Facilities
March 25, 2020
By: Matthew B. Kulkin, Micah S. Green, John T. Collins, Scott A. Sinder, James D. Barnette, Luis G. Fortuño, Jason Abel, George Callas, N. Hunter Johnston, Kate Jensen, Josh Oppenheimer, Anna M. Stressenger
Financial Services Group Advisory
US Financial Regulatory Response to COVID-19
March 24, 2020
By: Matthew B. Kulkin, Micah S. Green, John T. Collins, Scott A. Sinder, James D. Barnette, Luis G. Fortuño, Jason Abel, George Callas, Kate Jensen
Financial Services Group Advisory
Forecasting the CFTC's 2020 Agenda
January 23, 2020
By: Matthew B. Kulkin, Stacie R. Hartman, Charles R. Mills, Micah S. Green, Daniel A. Mullen, Michael V. Dunn, Richard Shilts, Josh Oppenheimer
Financial Services Group Advisory
Requestor Beware: CFTC Changes No-Action Publication Policy
January 13, 2020
By: Matthew B. Kulkin, Stacie R. Hartman, Charles R. Mills, Micah S. Green, Richard Shilts, Josh Oppenheimer
Events
Webinars
Post-Election Recap: Financial Services
November 12, 2020
Speakers: Alan Cohn, John T. Collins, Micah S. Green, Matthew B. Kulkin
Webinars
2nd Annual Regulatory Symposium: Elections Matter
October 22, 2020
Speakers: Christopher R. Conte, Micah S. Green, Matthew B. Kulkin, Marc L. Spitzer, Lisa M. Zarlenga
Webinars
Market Oversight and Regulation: FINRA and NFA Priorities and Practices
June 17, 2020
Speaker: Matthew B. Kulkin
Webinars
Perspectives from Washington: Navigating a Shifting Political, Regulatory, and Economic Environment
May 28, 2020
Speaker: Matthew B. Kulkin
On Demand
Lender Beware: Mitigating Risks in Lending Stimulus Funds to Small Businesses
May 6, 2020
Speakers: Michael Campion Miller, Stacie R. Hartman, Matthew B. Kulkin, Leah M. Quadrino, Ashwin J. Ram, Jeremy B. Glen
On Demand
Borrower Beware: Risks Associated with Accessing COVID-19 Relief Funds
April 14, 2020
Speakers: Matthew B. Kulkin, Michael Campion Miller, Leah M. Quadrino, Ashwin J. Ram, Jeremy B. Glen, Caitlin Conroy, Jason Meade
Webinars
Forecasting the CFTC's 2020 Agenda
March 3, 2020
Speakers: Micah S. Green, Stacie R. Hartman, Matthew B. Kulkin, Charles R. Mills, Daniel A. Mullen, Josh Oppenheimer
Webinars
Margin Treatment of Separate Accounts: Complying with Regulatory Requirements
December 11, 2019
Speakers: Matthew B. Kulkin, Stacie R. Hartman
Webinars
Legislative Oversight of the CFTC: A Primer
May 18, 2017
Speakers: Leslie A. Belcher, Michael V. Dunn, Micah S. Green, Matthew B. Kulkin, Darryl Nirenberg
Noteworthy
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Leadership Arlington, "40 Under 40" (2014)
Previous Employment
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Director, Division of Swap Dealer & Intermediary Oversight, Commodity Futures Trading Commission
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Legal intern, Bureau of Industry and Security, US Department of Commerce
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Judicial intern, Honorable Ellen Segal Huvelle, US District Court for the District of Columbia
Professional Affiliations
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Past co-chair, Derivatives, Securitization, and Project Finance Committee, DC Bar