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Tracy S. Combs

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries nationwide, including those involving the SEC, the Department of Justice, and state Attorneys General. She also counsels clients in complex business disputes, tort litigation, and cybersecurity matters. As Utah Business Journal’s Legal Elite edition stated in 2025, Tracy can “navigate a wide range of legal situations and…easily handle a crisis for any client.”

Tracy joined GT after an eight-year tenure at the SEC, where she served in a variety of roles in San Francisco and Salt Lake City. Most recently, Tracy served as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of its most high-profile cases. As a former SEC trial and investigative attorney in San Francisco, Tracy brought several groundbreaking enforcement actions, including the SEC’s first public company cybersecurity disclosure case and its first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s former Cyber Unit, where she co-led its Cybersecurity & Regulated Entities group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority matters and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.

Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.

On May 19, 2026, the CFTC’s Division of Enforcement replaced its 2025 tiered scoring matrix with a declination-first framework that imposes heightened self-reporting, cooperation, remediation, and restitution requirements on registrants seeking enforcement credit.

Continue Reading CFTC Division of Enforcement Issues New Cooperation Policy

On May 18, 2026, the SEC rescinded Rule 202.5(e), ending its decades-old prohibition on post-settlement public denials by settling parties. This shift removes a longstanding settlement friction point and may affect how companies and individuals approach SEC enforcement matters, public communications, and parallel litigation.

Continue Reading SEC Rescinds Longstanding ‘No-Deny’ Settlement Policy in Enforcement Actions

CFTC DoE Director David Miller highlighted prediction markets and crypto assets as perhaps the two most dynamic markets in finance during his March 2026 remarks at NYU Law School. 

Continue Reading Prediction Markets: A CFTC Enforcement Update

On March 17, 2026, the U.S. Securities and Exchange Commission issued an interpretive release addressing the application of the federal securities laws to crypto assets and related transactions.
Continue Reading SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework

On Aug. 21, 2025, Judge Margaret Ryan, a former senior judge of the United States Court of Appeals for the Armed Forces, was named the Securities and Exchange Commission’s director of the Division of Enforcement.
Continue Reading SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement Priorities

  • Increasing Focus on AI — AI developments and uses and the evolving legal and regulatory landscape may bring about new litigation and enforcement risks stemming from claims of algorithmic bias,
Continue Reading Outlook 2026: Financial Services Litigation

On July 18, 2025, President Trump enacted the GENIUS Act, the first comprehensive crypto legislation in U.S. history. The law introduces rigorous rules for payment stablecoins, including mandatory federal or state approval, 1:1 reserve backing, and enhanced disclosure obligations. Digital asset service providers must fully comply by July 2028.

Continue Reading GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States

On Feb. 25, the CFTC’s Division of Enforcement released an advisory highlighting the benefits of self-reporting, cooperation, and remediation for violations of the Commodities Exchange Act. It refines the Division’s approach, guiding how these factors influence enforcement recommendations.

Continue Reading CFTC Issues Enforcement Advisory on Benefits of Self-Reporting, Cooperation, and Remediation