Jeremy A. Liabo
Jeremy focuses his practice on futures and derivatives law. Jeremy regularly advises asset managers including mutual funds, hedge funds, private equity funds, family offices, endowments and insurance companies on commodities law matters including CPO/CTA registration, regulation and compliance issues. Jeremy has significant experience working with regulators, including the CFTC, NFA, futures exchanges and swap execution facilities, on behalf of clients in connection with regulatory inquiries, enforcement actions, regulatory audits and obtaining no-action relief.
In addition, Jeremy regularly advises “buy side” clients on derivatives and trading arrangements. Jeremy frequently represents public companies in connection with equity derivatives transactions, including accelerated share repurchase programs, capped calls and call spread overlays. Jeremy also has experience structuring and negotiating total return swaps.
Prior to joining Ropes & Gray, Jeremy was in-house counsel at a CFTC regulated futures exchange. While in law school, Jeremy was a legal intern with the CFTC’s Division of Enforcement.
- Co-author, “Amended CFTC Rules Provide Clarity For Asset Managers,” Law360 (February 6, 2020)
- Co-author, “Recent CFTC Enforcement Action against Non-U.S. Fund Manager for Violation of U.S. Position Limits Highlights Traps for the Unwary,” Wells Fargo Prime Service’s Industry and Regulatory Update (September 2019)
- Quoted, “CFTC proposal holds harsh surprise for asset owners,” Pensions & Investments (May 29, 2017)
- Co-author, “CFTC permits registered CTAs to use third-party recordkeepers: What CCOs need to know,” Compliance Reporter (May 24, 2017)
- Co-author, “NFA Inspections—Practical Guidance for CPOs and CTAs,” The Review of Securities & Commodities Regulation (February 18, 2015)
- Author, “CFTC Staff Issues Self-Executing Registration Relief for Certain Delegating CPOs,” Thomson Reuters’ Derivatives Financial Products Report (November 19, 2014)
- Author, “How to Approach New CPO Registration Relief” Compliance Intelligence (October 30, 2014)
- “The New Threat to Financial Reform: The End-User Exemption to Dodd-Frank Mandatory Swap Clearance,” 45 John Marshall Law Review 117 (2011)
- Co-author, “Disruptive Regulatory Practices - The New DCM Core Principles,” Futures Industry Association Conference Baltimore (May 2012)
- Presenter, “Hot Topics in Derivatives Regulation for Investment Managers using Commodity Interests (Futures, Options and Swaps),” Lawline (November 8, 2019)
- Presenter, “Industry Updates,” Chicago Bar Association’s Futures and Derivatives Law Committee (May 21, 2014)
- BA (Political Science), University of Iowa, 2006
- JD, cum laude, University of Illinois at Chicago John Marshall Law School, 2012; comment editor, The John Marshall Law Review
Admissions / Qualifications
- Illinois, 2012