Petal Walker

Special Counsel

Walker, Petal P.

Petal Walker counsels Financial Market Infrastructures (FMIs), banks and intermediaries, as well as innovators in the digital space, in meeting compliance obligations in a complex web of regulatory requirements. She advises companies on futures and swaps compliance and regulation and works closely with attorneys in banking, corporate and energy to deliver comprehensive, multi-faceted legal advice to clients. Ms. Walker rejoined WilmerHale in 2017 after serving as chief counsel for Commissioner Sharon Bowen at the CFTC, where she advised on policy and enforcement issues and served on the Market Risk Advisory Committee.

Ms. Walker also assists market participants by alerting them to the issues raised by, and helping them demonstrate compliance with, the requirements of the Dodd-Frank regulatory framework. Ms. Walker has rendered advice to CFTC registrants and end-users regarding the Dodd-Frank requirements in a number of areas, including reporting, mandatory clearing, product definition, segregation of customer funds, risk management and financial resource requirements. She also has enforcement and litigation experience, and has successfully assisted entities in responding to complex SEC and FINRA investigations.

As chief counsel for Commissioner Sharon Bowen at the CFTC, Ms. Walker advised Commissioner Bowen on a variety of significant derivatives-related issues, concerning FMIs—central counterparties (CCPs), exchanges, swap execution facilities and swap data repositories—including CCP resilience, recovery and resolution, equivalence, execution methods, algorithmic trading, and reporting requirements; intermediaries—including clearing members, swap dealers, and asset managers—on issues including portability, capital and margin, the de minimis requirement, and cross-border harmonization; and emerging technology market participants including issues such as FMI registration and the clearing obligation.     

Further, as designated federal officer for the CFTC's Market Risk Advisory Committee, Ms. Walker had a central role in forming the committee, overseeing its direction, and managing a two-year process to adopt well-regarded recommendations for CCP resilience. 

Prior to her three years at the CFTC, Ms. Walker was a senior associate at WilmerHale. 

Publications & News


February 21, 2018

On Diversity Panel, Petal Walker Emphasizes Importance of Inclusive Company Culture

At the recent European Financial Forum in Dublin, Ireland, Special Counsel Petal Walker spoke on a panel about diversity in the financial services industry. Walker, the former chief counsel to Commissioner Sharon Bowen of the Commodity Futures Trading Commission, emphasized the importance of diversity to a company's bottom line, as well as mentoring strategies that foster an inclusive culture.

November 29, 2017

US Department of the Treasury: A Financial System That Creates Economic Opportunities—Capital Markets

In October 2017, the US Department of the Treasury (Treasury) published a report titled “A Financial System That Creates Economic Opportunities” (Treasury Report). Treasury, under the direction of Secretary Steven T. Mnuchin, prepared the Treasury Report in response to Executive Order 13772 (Executive Order). The Executive Order established a set of Core Principles consistent with which the financial markets should be regulated.

October 3, 2017

Former CFTC Chief Counsel Petal Walker to Rejoin WilmerHale

Ms. Walker's practice will focus on advising companies on futures and swaps compliance and regulation in addition to other policy matters overseen by the CFTC.

August 20, 2014

DC Attorneys Lend Voices to Jumpstart’s 50 Reading Men Initiative

This summer, attorneys in WilmerHale's Washington DC office lent their voices to an important initiative aimed at helping preschool children in low-income neighborhoods develop the language and literacy skills they need to be prepared for kindergarten.

December 23, 2013

The Volcker Rule Handbook: A Detailed Look at the Final Rule Implementing Section 619 of the Dodd-Frank Act

Three and a half years after passage of the Dodd-Frank Act, the much anticipated final Volcker Rule has been issued.

November 6, 2013

CFTC Approves Proposed Rules on Position Limits

On Tuesday, November 5, 2013, the Commodity Futures Trading Commission (Commission) proposed new rules on speculative position limits and, separately, on the aggregation of related accounts

September 16, 2013

CFTC Concept Release on Automated Systems and Risk Controls

On September 12, 2013, the Technology Advisory Committee (“TAC”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) held a public meeting to discuss the CFTC’s recent Concept Release on Risk Controls and System Safeguards for Automated Trading (“Concept Release” or “Release”).1 Below are brief summaries of both the Concept Release and discussions held during the TAC meeting. We will provide a more comprehensive analysis of the Concept Release in the near future.

April 9, 2013

CFTC Staff Provides Broad Reporting Relief to Non-Financial End-Users

The Commodity Futures Trading Commission (CFTC) staff issued broad no-action relief to non-financial end-users from reporting requirements for new and historical swaps between corporate affiliates. This broad relief is self-effectuating and applies to swaps between wholly-owned or majority-owned affiliates of non-financial end-users where the affiliates’ financial results are included in the parent company’s consolidated financial statements. This relief will significantly reduce the reporting burden for non-financial entities that enter into inter-affiliate swaps.

January 9, 2013

The New Swaps Regime: A Primer for Nonfinancial Companies

October 16, 2012

CFTC’s New Regulations on the Clearing Activities of DCOs and FCMs to Address the New Risks Posed by Mandatory Clearing

An article co-written by Paul M. Architzel, published in Advanced Swaps & Other Derivatives 2012, Practising Law Institute, Corporate Law and Practice Course Handbook Series.

Professional Activities

Ms. Walker is a director on the Jumpstart DC Local Advisory Board as well as a member of the ABA Derivatives and Futures Law Committee Innovative Digitized Products and Processes Subcommittee; Derivatives, Securitization, and Project Finance Committee of the Corporation, Finance and Securities Section of the District of Columbia Bar Association; the Derivatives and Futures Law Committee of the Business Law Section of the American Bar Association; Women In Derivatives (WIND); and Women In Energy (WEN). 


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JD, Harvard Law School, 2008

EdD, Harvard Graduate School of Education, 2007

MA, Comparative Education, Columbia University, 1999

BA, History, summa cum laude, with Distinction, Yale University, 1995, Phi Beta Kappa

Bar Admissions

District of Columbia


Government Experience

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