Matthew B. Comstock attorney profile image
Practice Areas
  • LL.M., Universität Augsburg, Germany, 1995
  • J.D., University of Pittsburgh School of Law, 1995
  • M.B.A., University of Pittsburgh, Joseph M. Katz School of Business, 1995
  • B.A., Economics, University of Pittsburgh, 1991
  • District of Columbia
  • New Jersey
  • Pennsylvania

Matthew B. Comstock
1001 G Street, N.W.
Seventh Floor
Washington, DC 20001
T: (202) 661-7034
F: (202) 661-7059


  • CLIENT ALERT - S. 945
    (Co-authored with Larry E. Bergmann, Robertson Park)

    United States Senate Acts to Address Concerns About Audit Integrity of Foreign Issuers Trading on United States Markets – With a Focus on Chinese Companies.

  • Chambers USA 2020 Recognizes Firm, Lawyers
    (Co-authored with Stephen J. Crimmins, Howard L. Kramer)

    Murphy & McGonigle has once again received both noteworthy firm and multiple lawyers’ recognition in the new edition of Chambers USA, which was recently published.

  • Surprise: SEC Opens the Sandbox
    (Co-authored with Larry E. Bergmann)
    Blockchain Law Center | (10/31/2019)

    The staff of the SEC’s Division of Trading and Markets has issued a no-action letter that permits Paxos Trust Company, LLC (“Paxos”) to operate a limited type of blockchain-based clearing agency.  Although the no-action letter places tight limits on who and what can clear and settle securities transactions through the Paxos system, and how that settlement has to occur, this is the first time the SEC has allowed market participants to operate in regulatory sandbox.

  • SEC Staff Issues Second Utility Token No-Action Letter
    (Co-authored with Larry E. Bergmann, Macauley B. Venora)

    The staff of the Division of Corporation Finance issued the second no-action letter permitting an unregistered token offering and sale for use on a functional platform.

  • The staffs of the SEC's Division of Trading and Markets and FINRA issued their first public statement on broker-dealer custody of digital securities on July 8, 2019.  Among other things, the staffs discuss potential approaches for broker-dealers to carry digital securities in compliance with Rule 15c3-3 under the Exchange Act.

  • The SEC's Division of Corporation Finance issued both a "Framework for 'Investment Contract' Analysis of Digital Assets" and a no-action letter relating to a blockchain-based consumptive token on April 3, 2019.  The Framework is intended to be a plain English description of how the SEC staff applies the so-called Howey test to determine if a digital asset is a security under the federal securities laws.  It also adddresses the concept of mutability of a digital asset whereby a digital asset initially issued as a security later converts to a digital asset that is not a security because of the digital asset's use on a fully-functional platform, among other things.

    The Division also issued a no-action letter to an air charter services company, TurnKey Jet, Inc.  The no-action letter permits TurnKey to issue a consumptive/utility token, subject to the criteria set out in the letter.