Mr. Comstock has a diverse practice covering all aspects of the broker-dealer and trading and markets business. He regularly advises broker-dealer, hedge fund and other clients on a variety of transactional, compliance and regulatory matters. His areas of expertise include broker-dealer financial responsibility, broker-dealer liquidations, securities credit regulation, compliance with self-regulatory organization rules, short selling, regulations governing market manipulation, securities lending, soft dollars, prime brokerage, and market structure. He has particular experience and expertise dealing with the provisions of the Dodd-Frank Act applicable to broker-dealers, including provisions relating to securities-based swap dealers.
Mr. Comstock’s recent significant matters include representing major financial services firms in matters relating to cross-border broker-dealer registration and operations issues and in developing novel and complex investment products and services.
Mr. Comstock was an attorney in the SEC’s Division of Trading and Markets, where he held the positions of Branch Chief, Special Counsel and Staff Attorney in the Office of Financial Responsibility. He had responsibility for a variety of matters relating to broker-dealer net capital requirements, customer protection, broker-dealer books and records requirements, margin and broker-dealer liquidations.