Career
Prior to his CFTC service,Behnam served as senior counsel on the Senate Committee on Agriculture,Nutrition,and Forestry for U.S. Senator Debbie Stabenow of Michigan. He has also worked on a proprietary equities trading desk,practiced law in New York City and with the Bureau of Securities in the state of New Jersey’s Office of Attorney General,and co-founded a short-lived regional commuter airline.
Government service
Behnam’s major responsibilities included advising Senator Stabenow on the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act and related matters affecting the Treasury Department,the U.S. prudential regulators [8] (safety and soundness),and the Securities and Exchange Commission. Behnam also focused on legislative issues regarding agricultural biotechnology and crop protection issues.
Behnam worked alongside Chairwoman Stabenow during her successful effort in leading passage of the bipartisan 2014 U.S. Farm Bill. [9] During that time,Behnam focused on the new and evolving risks for the agricultural economy and strengthening legacy risk management programs. Stabenow’s unique focus on risks related to climate change,highlighted by the numerous climate related disasters agricultural producers and rural communities faced leading up to 2014, [10] helped garner support for the inclusion of a wide range of programs in the final law. The 2014 Farm Bill enhanced the federal crop insurance program, [11] revised commodity programs,and retroactively authorized multiple disaster programs beginning in FY2012. [12] Many of these same programs were strengthened and included in the 2018 U.S. Farm Bill. [13]
Behnam played a key role in drafting the 2016 GMO labeling bill. [14]
Behnam is recognized as an early advocate for exploring climate-related financial risk [15] in the derivatives markets and larger economy and the appropriate role for market regulators. [16] Recognizing that weather and climate present risks to economic productivity,financial stability,and household wealth,Behnam led the creation of the Climate-Related Market Risk Subcommittee [17] within the CFTC’s Market Risk Advisory Committee to examine climate-related impacts on the financial system. The Subcommittee’s efforts resulted in the September 2020 release of the report Managing Climate Risk in the U.S. Financial System, [18] the first of-its-kind effort from a U.S. government entity. [19] Behnam followed its release with testimony before the House Select Committee on the Climate Crisis [20] and presentations in other venues focused on climate-related market risk and incorporating sustainability resilience into U.S. and global financial systems. [21]
Behnam established the Climate Risk Unit or “CRU”within the CFTC to focus on the role of the derivatives markets,and the CFTC as a market regulator,in understanding,pricing,and addressing climate-related risk. [22] Climate change has been identified as an emerging threat to U.S. financial stability, [23] and Behnam asserts that the CFTC’s unique mission focused on risk mitigation and price discovery puts the agency on the front lines of mitigating climate change.
In December 2023,Behnam participated in COP28 where he delivered keynote remarks on voluntary carbon markets and announced the CFTC’s proposal of the first federal guidelines for voluntary carbon credit derivative contracts. [24] Behnam’s announcement was praised by Treasury Secretary Janet Yellen and John Kerry,U.S. Special Envoy on Climate.
Views and opinions
An advocate for the financial reform efforts born out of the Global Financial Crisis [25] ,Behnam supported completion and ongoing revision of rules implementing the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. [26]
Behnam has led initiatives to address ongoing and emerging risks related to LIBOR reform,climate-related market risk,retail participation in the digital asset commodity markets,risk concentration within financial market infrastructure,and diversity,equity,and inclusion (DEI) in the CFTC and larger derivatives and financial markets. [27] He is an advocate for federal regulation of the digital asset markets,calling on the White House for leadership and testifying before Congress on the subject. [28]
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