Mr. Comstock, a former lawyer at the U.S. Securities and Exchange Commission, has a diverse practice covering the legal and regulatory aspects of securities trading and markets, including the application of securities regulation to digital assets issued on the blockchain and to technological developments in the securities industry more broadly. He regularly advises trading platforms, broker-dealers, clearing agencies, hedge funds and other clients on a variety of compliance, regulatory and transactional matters, and interfaces with the staff of the SEC and other regulatory bodies on behalf of clients. His areas of expertise include creation of trading platforms, custody and trading of alternative investments/digital assets, broker-dealer financial responsibility, broker-dealer liquidations, securities credit regulation, compliance with self-regulatory organization rules, short selling, regulations governing market manipulation, securities lending and securities repurchase transactions, soft dollars, prime brokerage, and market structure.

Mr. Comstock’s recent significant matters include assisting in the creation of a trading platform for digital assets, establishing cryptocurrency trading desks, assisting a broker-dealer with a FINRA examination and investigation regarding complex financial responsibility issues, and representing a leading global derivatives marketplace with respect to regulatory matters before the SEC’s Division of Trading and Markets.

A member of Murphy & McGonigle’s FinTech and Blockchain Practice, Mr. Comstock is a regular speaker at financial industry and blockchain events, and he is one of five authors of Murphy & McGonigle’s proprietary report, Cryptocurrency Regulatory Developments.

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.

Publications

• SEC’s Ultimatum to Token Platforms is No Choice at All: Register as an ATS or Go Out of Business
  (Co-authored with James Dombach)
  (03/14/2018)
  
• SEC Staff Discusses Tokens at SEC Speaks in 2018
  Blockchain Law Center | (02/23/2018)
  
• SEC Enforcement Reminds Social Media Influencers Pushing ICOs and Other Investments to Comply with Federal Securities Laws
  (Co-authored with Daniel M. Payne)
  (11/06/2017)
  
• Regulators and Industry Groups Continue Blockchain Efforts
  HYPERLEDGER | (04/14/2017)
  
• SEC Ramps-Up Blockchain Efforts
  The Hill | (12/19/2016)
  
• SEC Initiates Flash Boy Regulations – A Comprehensive Analysis
  10/07/2014 | (10/07/2014)
  
• Supervisory obligations of broker-dealer legal and compliance personnel after the Urban case
  (Co-authored with Howard L. Kramer)
  Journal of Investment Compliance | (June, 2012)
  
• SEC Adopts Large Trader Reporting System
  (Co-authored with Howard L. Kramer)
  Journal of Investment Compliance | (November, 2011)
  

Seminars and Presentations

• FinTech Junction 2018
  06/24/2018
• SEC Initiates Flash Boy Regulations – A Comprehensive Analysis
  10/07/2014

In the News

• Murphy & McGonigle First Law Firm to Join Hyperledger Project
  (11/01/2016)
  
• Former SEC Official Joins Murphy & McGonigle
  PR Newswire | (06/07/2012)