Jeannette K. Boot


Boot, Jeannette K.

Jeannette Boot advises both sell-side and buy-side clients with respect to trading agreements and transactions, including ISDA documentation, futures, prime brokerage, term commitments, stock lending, repo, custodial arrangements, electronic services agreements and a wide range of derivatives products, both over-the-counter and cleared.

Ms. Boot's practice includes working with swap dealers to create templates for various counterparty-facing transactions. She also works closely with the firm's Broker-Dealer Compliance and Regulation Group to assist dealer clients with regulatory issues related to swaps. In connection with this advice, Ms. Boot has worked with clients on a wide variety of compliance issues related to Dodd-Frank and EMIR. In addition, she provides advice regarding various securities laws issues, including concerns related to insider trading and market manipulation.

Ms. Boot also advises corporate clients with respect to all types of derivatives transactions. This includes negotiating ISDA master agreements and interest rate swaps in connection with credit facilities, negotiating various F/X arrangements and negotiating more bespoke equity derivatives transactions, including call spreads, accelerated share repurchases and forward share repurchases and sales.

Additionally, Ms. Boot has provided advice in connection with various litigation and enforcement matters. She has teamed up with WilmerHale's bankruptcy practice in connection with a number of Lehman-related matters, including two matters that are actively being litigated in bankruptcy court. Ms. Boot is the co-author of two amicus briefs on behalf of ISDA in Lehman cases, and has developed thorough knowledge of bankruptcy safe harbors for swaps, securities agreements and repurchase agreements. Ms. Boot has also worked on several large investigations on behalf of financial institutions clients.


Prior to joining the firm, Ms. Boot served as general counsel for Och-Ziff Capital Management Group, an institutional asset manager, where she was primarily responsible for trading advice and transaction documentation. Before her work with Och-Ziff, Ms. Boot was counsel at Davis Polk & Wardwell in New York, where she worked in the Equity Derivatives and Financial Institutions Groups. There, her practice focused on a wide range of derivatives, structured products and trading-related matters, and included representation of many of the world's largest financial institutions and hedge fund managers. 

In December 2017, Ms. Boot successfully completed a 40-hour mediation and conflict resolution training program with The Center for Understanding In Conflict.

Honors & Awards

  • Recipient of WilmerHale's "2008 Mentor of the Year Award" in recognition of her generosity and effectiveness in helping associates develop and grow professionally

Publications & News


November 9, 2016

CFTC Revises Proposed Reg AT

The Commodity Futures Trading Commission on November 3, 2016, proposed revisions  to proposed Regulation Automated Trading (Reg AT). Reg AT, if adopted, will broadly affect those in the futures industry who trade electronically, imposing new registration and supervision requirements on algorithmic traders.

July 18, 2016

WilmerHale Advises Intercept Pharmaceuticals in $460M Public Offering

Intercept Pharmaceuticals, Inc., a biopharmaceutical company focused on the development and commercialization of novel therapeutics to treat non-viral, progressive liver diseases, has announced the closing of an underwritten public offering of $460 million aggregate principal amount of 3.25% convertible senior notes due 2023.

February 11, 2016

SEC Adopts Rules on Non-US Firms That “Arrange, Negotiate, or Execute” Security-Based Swaps in the US

The Securities and Exchange Commission (SEC) adopted rules that will affect firms operating in the global security-based swap market. Specifically, the SEC is requiring non-US firms that arrange, negotiate, or execute security-based swaps using personnel located in the United States to include those security-based swaps in their calculations of whether they reach the threshold requiring security-based swap dealer registration.

January 26, 2016

2015 CFTC Year-in-Review, and a Look Forward

CFTC continues to bring high-profile, large-penalty enforcement cases; begins bringing cases to enforce Dodd-Frank Act implementing regulations; and embarks on post-Dodd-Frank Act regulatory initiatives.

December 15, 2015

CFTC Proposes “Regulation AT” for Automated Trading

On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or the proposal).

September 29, 2015

CFTC Updates Position Limits Rule

On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the requirements in the proposed rules regarding the aggregation of positions subject to the Commission’s speculative position limits. Specifically, the proposal would modify the eligibility criteria and simplify the process for claiming an exemption from the aggregation requirements for owners of more than 50 percent of another entity.

April 30, 2015

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

On April 29, 2015, the US Securities and Exchange Commission proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States.

June 24, 2014

Navigating the CFTC's Cross-Border Guidance – A Primer for Market Participants

An article by Jeannette Boot and Gail Bernstein, published in the May 2014 edition of Futures & Derivatives Law Report, Vol. 34, Issue 5.

May 1, 2014

CFTC Issues Oral Recordkeeping No-Action Relief to Asset Managers

On April 25, 2014, the Commodity Futures Trading Commission (CFTC) extended time-limited no-action relief for certain asset manager members of swap execution facilities (SEFs) and designated contract markets (DCMs) from the oral recordkeeping requirement of CFTC Regulation 1.35(a) in connection with the execution of swaps.

July 1, 2013

Thermo Fisher Completes $2.53 Billion Common Stock Offering

A team of WilmerHale transactional lawyers represented Thermo Fisher Scientific Inc. in its recently completed $2.53 billion underwritten public offering of its common stock made in connection with the forward sale agreements described below.

Speaking Engagements


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JD, cum laude, Harvard Law School, 1995

BA, Slavic Languages and Literatures, with highest honors, University of California, Berkeley, 1991

Bar Admissions

New York


The Hon. Jose A. Cabranes, US Court of Appeals for the Second Circuit, 1996 - 1997

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