De’Ana Dow Reflects on Trailblazing Regulatory Career and FIA Hall of Fame Induction: From Audit Trails to Advocacy

De'Ana Dow
John Lothian

John Lothian

Executive Chairman and CEO

At the FIA International Futures Industry Conference in Boca Raton, FL, De’Ana Dow, partner at Capitol Counsel LLC and inductee into the FIA Hall of Fame Class of 2024, was interviewed by John Lothian News. Dow expressed surprise at her Hall of Fame nomination, saying, “I was completely shocked… never in a million years did I think I’d be considered, let alone selected.”

Dow described the audit trail rule as the most challenging yet rewarding project she worked on during her tenure at the CFTC, emphasizing its complexity at the time. Her work on the audit trail rule was a springboard to new roles, from counselor to commissioner. “That was a huge issue back in the day… everything was manual. We reviewed trading cards manually,” she said, highlighting the contrast to today’s nanosecond trading times.

Dow also shared the satisfaction she found in transitioning the CFTC to core principles-based regulation, which allowed for more flexibility and “allowed the industry to grow by leaps and bounds,” she said. “It was the most interesting rulemaking that I worked on,” Dow said.

Reflecting on her challenges at NYMEX, Dow said it was “baptism by fire” as she discussed her efforts to counteract price limit legislation that threatened the WTI crude contract and rid it of speculators, emphasizing the importance of maintaining market liquidity. “Gas prices were high, and that was the solution they’d (Congress) come up with… So my job was to kill that draft bill,” she said.

Her experiences with Congress and lobbying taught her the complexity of influence and regulation in Washington. Dow appreciated the trust she earned as a former regulator, saying, “They trusted the fact that I really understood the markets.” 

Representing NYMEX before the CFTC felt natural to Dow, given her history with the agency. “It was pretty easy because the CFTC, that was my family,” she said, adding that her familiarity with the agency’s expectations helped her ensure that NYMEX’s submissions were up to standard. All CFTC submissions went through Dow as a result of her quality control skills. 

Looking back on the changes in the industry, Dow pointed to the expansion of the commission’s jurisdiction into swaps as the most significant, saying, “That expansion… was very industry-changing for not only the futures business but for the swaps business as well. So that I think was probably what would be the wow factor for me.”


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