Washington, D.C
Jun 15, 2021
Jun 19, 2021
Full Time


This Division of Data (DOD) serves as the leading authority on the Commission's data strategies. The DOD is comprised of two branches, Data Policy and Standards and Data Operations. If selected for this position, you will serve as Counsel within the Data Policy Section and perform work that involves extremely complex and difficult legal questions, policy choices, or factual/technology/data issues.

Learn more about this agency


At the CT-12 level of this position, you will perform the following duties;
  • Works with a team on the review of applications by entities seeking to become registered as SDRs. You will also assist in overseeing the operation of SDRs under Commodity Exchange Act (CEA) section 12a and 24a and Part 49 of the Commission's regulations. To this end, you will review the applications for SDR registration to ensure compliance with applicable core principles and Commission rules and policies. On a continuous basis, the Branch will oversee how the SDR accepts, maintains, and provides access to data and will review governance, compliance officer, and conflicts-related rules of SDRs. You will also review Chief Compliance Officer annual reports and SDR quarterly financial reports to assure that the SDR's rules, operations, procedures, and practices meet the statutory standards of the CEA and the Commission's regulations and policies.
  • Reviews applications of entities that apply for registered entity status such as Designated Contract Markets (DCMs), Swap Execution Facilities (SEFs), Derivatives Clearing Organizations (DCOs), as well as Foreign Boards of Trade (FBOTs), for compliance with their particular reporting obligations under the Commission's regulations. The reviews must be completed within specified statutory time frames or regulatory deadlines. As a participant within a review team, the incumbent will assess among other things, the applicant's compliance with statutory requirements and core principles and the Commission's regulatory interpretations and policies thereunder. The reviews involve a comprehensive analysis and evaluation of the applicant's governance provisions, rules, and all aspects of the SDR's operations.
  • Supports overseeing entities' compliance with certain data and reporting requirements under the CEA sections and Commission regulations including, but not limited to, CEA sections 2(a)(13), 2(h), 4(r), 5(b), 5(h), 8, and 21 and parts 39, 43, 45, 46, 49, and 50 of the Commission's regulations and the implementation of and compliance with any amendments or changes to those sections with respect to data and reporting.
  • Reviews initial and ongoing filings of registered entities as related to the Commission regulations above and reporting of data in general to determine the sufficiency of such filings in meeting the requirements of the Act and the Commission's regulations.
  • Reviews market-related requests for approval and rule certification filings submitted by registered entities and no action relief requests related to data reporting. These filings relate to, among other things, rule submissions and/or Form SDR modifications for changes in procedures of registered entities related to reporting swaps data.
  • Supports determinations of whether rule filings or no action relief requests are in compliance with the Act, Commission regulations, and policies; consistent with general legal principles; accurately drafted; and reasonable in light of reporting conducted by other registrants or market participants, or other practical or operational considerations.
  • Participates in preparing the Federal Register notice, summarizing comments, summarizing testimony, and making recommendations for further revisions.
  • Analyzes proposed legislation related to oversight of markets to identify the possible effects of such legislation upon regulated, exempt and excluded entities and the public.
  • Researches and maintains knowledge of the CFTC's regulations and policies, including with changes in applicable law and developments in the derivatives industry.
    Performs other duties as assigned.

Travel Required

Not required

Supervisory status

Promotion Potential


Conditions of Employment

  • U.S. Citizenship
  • Males born after 12-31-1959 must be registered for Selective Service
  • Two year trial period may be required

Bar Membership: Currently an active member in good standing of the bar of a state, territory of the United States, District of Columbia, or Commonwealth of Puerto Rico.

Applicants are responsible for citing minimum qualifications such as JD and Bar membership information (institution name, state for bar, and dates) on their respective resumes. Failure to supply details will result in an incomplete application.


To qualify at the CT-11 level, applicants must have:
  • A law degree (J.D. or equivalent), Superior Academic Achievement and bar membership, OR
  • A law degree (J.D. or equivalent), bar membership, and 1 year of relevant legal experience after completion of law school.

To qualify at the CT-12 level, applicants must have:
  • A law degree (J.D. or equivalent), bar membership, and 2 years of relevant legal experience after completion of law school.

Specialized experience must include:

•Demonstrated skill in research and analysis of sophisticated legal issues, as well as excellent written and oral communication skills.

•Knowledge of commodities or related law and regulations, financial markets, corporate law, and general administrative law.

•Knowledge of derivatives markets, including futures, options, and swap markets, and clearing for these markets.


Successful completion of a full course of study (JD) in a school of law accredited by the American Bar Association (ABA).

Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education .

SPECIAL INSTRUCTIONS FOR FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show that the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. For further information, visit:

Additional information

Relocation. Relocation expenses will not be paid.

Trial Period. You may be subject to a two year trial period.

Additional selections may be made from this announcement.

Veterans' Preference: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Commodity Futures Trading Commission considers veterans' preference eligibility as a positive factor in attorney hiring. Applicants eligible for veterans' preference must indicate their preference in response to the appropriate question in their assessment questionnaire (it is also recommended that information is included in their cover letter or resume) and they must submit supporting documentation (e.g., DD 214, Certificate of Release or Discharge from Active Duty and other supporting documentation) which verifies their eligibility for preference. Although the "point" system is not used, per se, applicants eligible to claim 10-point preference must submit Standard Form (SF) 15, Application for 10-Point Veteran Preference, and submit the supporting documentation required for the specific type of preference claimed (visit the OPM website, for a copy of SF 15, which lists the types of 10-point preferences and the required supporting document(s). Applicants should note that SF 15 requires supporting documentation associated with service-connected disabilities or receipt of non service-connected disability pensions to be dated 1991 or later except in the case of service members submitting official statements or retirement orders from a branch of the Armed Forces showing that his or her retirement was due to a permanent service-connected disability or that he/she was transferred to the permanent disability retired list (the statement or retirement orders must indicate that the disability is 10% or more).

EEO Policy Statement. The United States Government does not discriminate in employment on the basis of race, color, religion, sex, national origin, genetic information, political affiliation, sexual orientation, marital status, disability, age, membership in an employee organization, or other non-merit factor.

Reasonable Accommodation. Federal agencies must provide reasonable accommodation to applicants with disabilities where appropriate. Applicants requiring reasonable accommodation for any part of the application and hiring process should contact the hiring agency directly. Determinations on requests for reasonable accommodation will be made on a case-by-case basis.

The law prohibits public officials from appointing, promoting, or recommending their relatives. The law prohibits requesting, making, transmitting, accepting, or considering political recommendations for employment or other personnel actions for non-political positions. This includes recommendations from Members of Congress, Congressional employees, elected state or local officials, and political party officials and any recommendation based on party affiliation.

How You Will Be Evaluated

You will be evaluated for this job based on how well you meet the qualifications above.

This job is being filled under a Schedule A hiring authority 5 CFR 213.3102 and is excepted from the competitive civil service. These positions are not covered by the usual civil service hiring procedures. There is no numerical rating system through which to apply veterans preference; however, CFTC considers veterans' preference eligibility as a positive factor in hiring. Applicants eligible for veterans' preference are encouraged to include that information in their cover letter or resume, and to attach supporting documentation (e.g., the DD Form-214 or other substantiating documents) to their submissions.

Your resume will be referred to the selecting official for the initial review of qualifications. This does not mean you are considered highly qualified for the position. The HR Specialist will ensure the selectee meets all requirements, including education and minimum qualifications listed on the vacancy announcement. A complete application package is required to be considered qualified and eligible for selection. Please review the "Requirements" section of the vacancy announcement to understand the list of required documents for a complete application package. Additional information may be requested later in the recruitment process.

To preview questions please click here .

Background checks and security clearance

Security clearance
Not Required

Drug test required

Position sensitivity and risk
Moderate Risk (MR)

Trust determination process
Credentialing , Suitability/Fitness

Required Documents

Submission of a resume alone IS NOT a complete application. You must provide a complete Application Package to be found qualified and eligible for this position. You may be required to provide additional documentation at a later time in the recruitment process. All documentation will be required prior to finalizing selections and job offers. You may be disqualified if you fail to submit a completed application package.
    • Cover Letter including a statement of interest (optional)
    • Resume (must include education, including name of undergraduate and law school, degree received and date graduated; date admitted to bar and jurisdiction; a general description of all past employment relevant to the practice of law, including dates of employment and supervisor(s) name(s) and telephone number(s). You may add a notation asking to be notified prior to OGC contacting the listed supervisor.
    • Writing sample, illustrating relevant experience
    • Law school transcripts (final copy with date degree was awarded)
    • Proof of active bar membership/status in good standing and eligibility to practice law in state, U.S territory, the District of Columbia, or the Commonwealth of Puerto Rico

If you are relying on your education to meet qualification requirements:

Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education .

Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating.