Photo of Tracy S. Combs

A former Regional Director at the U.S. Securities and Exchange Commission, Tracy counsels corporations, financial institutions, and individuals regarding complex investigations, litigation, and regulatory matters, including those involving the SEC, the Department of Justice, the Commodity Futures Trading Commission, and other law enforcement agencies and financial regulators.

On Oct. 22, 2024, the SEC announced settled administrative actions against four current or formerly public technology companies, finding that the companies all made materially misleading disclosures to investors in

Continue Reading SEC Files Actions Against 4 Public Companies for Negligent Cybersecurity Disclosures

The Securities and Exchange Commission’s Division of Examinations (Division) announced its 2025 examination priorities (Exam Priorities) Oct. 21, 2024. These priorities address areas of concern based on recent examinations, and

Continue Reading SEC Division of Examinations 2025 Priorities

In the latest installment of its ongoing “off-channel” communications sweep, on Aug. 14, 2024, the Securities and Exchange Commission announced settlements totaling $393 million with 26 investment advisers and brokers-dealers

Continue Reading SEC Collects $390 Million in Latest Crackdown on ‘Off-Channel’ Communications in the Financial Industry

On Aug. 9, 2024, the Securities and Exchange Commission initiated administrative and cease-and-desist proceedings against a U.S. registered investment adviser (the Adviser). This action resulted from the Adviser’s failure to

Continue Reading SEC Cracks Down on Marketing Rule Violations: Takeaways for Investment Advisers

On July 30, 2024, the SEC announced it had reached a settlement agreement with Western, a dually registered investment adviser and broker-dealer providing investment advice and brokerage services to retail

Continue Reading Reg BI Enforcement Intensifies: SEC Fines Western International Securities for Violating Care and Compliance Obligations