Mr. Patent regularly counsels businesses with respect to commodity interest trading compliance and the legal requirements governing trading in over-the-counter derivatives and exchange-traded futures, including both international and U.S. markets. His clients include, among others, hedge funds, currency dealers, commodity pool operators, commodity trading advisors, futures commission merchants, and introducing brokers. He services diverse client needs, including advice regarding the registration, disclosure, and other regulatory requirements of the Commodity Futures Trading Commission (“CFTC”) and National Futures Association (“NFA”), preparation of internal compliance procedures and policies for trading operations, time-sensitive legal advice concerning particular market positions and strategies, and compliance training. Mr. Patent has been very active in all phases of the financial regulatory reform (“Dodd Frank”) process, including both the legislative and implementation aspects. Mr. Patent has been recognized as a leading lawyer for his work in the practice area of Derivatives and Futures Law in the 2013, 2014, and 2015 editions of The Best Lawyers in America®.
Mr. Patent joined K&L Gates in 2008 after serving more than thirty years as an attorney with the CFTC, the last five as the Deputy Director of the Division of Clearing and Intermediary Oversight.
Prior to joining K&L Gates, Mr. Patent served as deputy director of the Division of Clearing and Intermediary Oversight at the CFTC. Mr. Patent worked at the CFTC in various capacities for more than 30 years. He was the principal drafter of many CFTC regulations regarding intermediaries, including the original regulations governing introducing brokers in 1983 and the last major general reform of intermediary regulation in 2000, and he supervised the preparation of many important CFTC staff interpretive letters. He represented the CFTC in its dealing with other regulators, particularly the Securities and Exchange Commission (“SEC”), on issues relating to intermediaries, and is quite familiar with relevant regulations of the SEC and the Financial Industry Regulatory Authority. Mr. Patent was the original Chair of the Registration Working Group, which is composed of CFTC and NFA staff and meets several times a year to discuss issues relating to registration of intermediaries. Mr. Patent also worked with various foreign regulatory bodies in connection with review of their regulatory frameworks.