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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 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

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