- Audit, Accounting & Financial Reporting
- Cybersecurity, Cybercrime, & Incident Response
- FinTech & Blockchain
- Independent Monitoring & Independent Consulting
- Private Funds Advisory & Enforcement Defense
- Regulatory Enforcement Defense
- Securities Arbitration & ADR
- Securities & Complex Commercial Litigation
- White Collar Defense, Investigations & Compliance Counseling
- J.D., Columbia Law School
- B.A., Fordham University
- District of Columbia
- New York
- U.S. Supreme Court and lower federal courts
Steve Crimmins defends clients in enforcement matters involving the Securities and Exchange Commission and other financial regulators.
Steve is consistently ranked at the top of his practice area, based on peer reviews. Best Lawyers in America named him the “Securities Regulation Lawyer of the Year for New York City” based on a 2017 survey of New York peers, and ranks him nationally for both securities litigation and securities regulation. Chambers USA ranks him nationally for “complex and sensitive SEC enforcement actions and investigations on behalf of public companies and broker dealers,” with “significant strength in financial fraud and accounting issues.” Chambers reports that peers call him a “real leader of the SEC enforcement Bar” (2019) and “a wonderful guy, steeped in securities law” (2020), and comment that “you will find no one who knows more about how to litigate at the SEC” (2018). Securities Docket has repeatedly given him its Enforcement 40 award as among the nation’s “best and brightest securities enforcement defense attorneys.”
Steve chaired both the Federal Bar Association’s Securities Law Section, and the DC Bar’s Corporation, Finance and Securities Law Section. He has testified three times before the U.S. House of Representatives, most recently in 2019 at a Financial Services Committee hearing on SEC enforcement reforms and on cryptocurrency regulation, and twice during the financial crisis. He regularly speaks on securities law panels and is quoted in the national business news media on SEC enforcement issues. He writes on a variety of securities topics, including a scholarly article “Insider Trading: Where Is the Line?” in the Columbia Business Law Review that was noted in The Economist. He has in recent years repeatedly guest-taught law classes on SEC enforcement topics at Columbia Law School and Georgetown Law Center.
During 14 years at the SEC, Steve managed the Enforcement Division’s large Trial Unit in prosecuting jury and non-jury securities cases in federal court and administrative proceedings, while also participating in investigations and settlements. First joining the SEC as a senior trial counsel in Washington, Steve continued to personally litigate and try cases after promotion to Enforcement Division leadership and the Senior Executive Service. He earned the SEC-wide Productivity Improvement Award for his management skills. A Brooklyn native, he began his career at a large New York law firm after graduating from Columbia Law School.
Since returning to private practice well over a decade ago, Steve has helped many entities and individuals successfully resolve securities enforcement matters. He is presently defending clients in ongoing SEC multi-party investigations, as well as in SEC litigation and shareholder litigation now pending in federal and state courts in New York, Boston, Chicago and elsewhere, and in SEC administrative proceedings. In 2019, he was lead trial counsel in an SEC administrative proceeding in Washington DC in a case charging frontrunning, and settled SEC litigation in federal court in Baltimore in a revenue recognition matter. In another SEC administrative proceeding, he won unanimous affirmance by the SEC Commissioners on expanded grounds of his trial victory dismissing fraud charges against a large custodial services company. While prepared to litigate, he achieves negotiated outcomes without litigation, including recent settled SEC insider trading charges and FINRA market manipulation charges. He recently served as “pool” counsel for over 30 public company officers and employees during internal and follow-on SEC investigations of revenue recognition issues. He regularly teams with other law firms as securities co-counsel.
Steve defends the full range of enforcement issues – financial reporting, accounting, disclosures, insider trading, funds, advisers, trading rules, manipulation, cryptocurrency, complex products, municipal finance, FCPA, cybersecurity, professional bars and other matters. He provides strategic representation before and during investigations. He advocates in meetings with regulators, white papers, Wells submissions, and settlement negotiations. Where matters must be contested, he fights for clients in trials and appeals in federal court and administrative proceedings.
Lead trial counsel in August 2019 in the trial of an SEC administrative proceeding alleging front-running by an investment adviser. Matter of Gibson, SEC File No. 3-17184
Obtained a non-fraud and no-admission settlement for senior corporate officer in October 2019 at the conclusion of pretrial discovery in a litigated SEC federal court case charging revenue recognition fraud. SEC v. Jacoby (Osiris Therapeutics), 2017 WL 5067468 (D. Md.).
Pool counsel for over 30 non-charged executives and employees during investigations leading to a settled SEC case filed in September 2019 involving a public company’s financial reporting. Matter of ComScore Inc., SEC File No. 3-19499.
Counsel for investment adviser in pending SEC case, filed August 2019, involving revenue sharing disclosure issues. SEC v. Commonwealth Financial, 19-cv-11655 (D. Mass.).
Successfully defended the nation’s leading self-directed IRA custodian at a multi-week trial before an SEC ALJ resulting in a decision dismissing all charges, and then obtained a unanimous decision by the SEC Commissioners affirming this trial win on expanded grounds. Matter of Equity Trust Company, 2017 WL 4335067 (Sept. 28, 2017).
Settled SEC federal court charges in December 2019 against a securities trader involving alleged record-keeping violations. SEC v. Mattessich and Ludovico, 2018 WL 3207310 (S.D.N.Y.).
Settled without admissions FINRA “layering and spoofing” manipulation charges against alleged controlling person of two funds pursuing so-called global day trading strategies. FINRA AWC 2012031480722 (reported in Wall Street Journal, Sept. 18, 2018, p. B1).
As lead trial counsel, settled one day before trial without admissions in SEC proceeding relating to investment adviser’s recommendations to public pension plans. Matter of Gray Financial Group, Inc., 2017 WL 5624487 (Nov. 22, 2017).
Settled without admissions, without professional bar, and in an administrative order, an SEC insider trading case against an attorney. 2018 WL 3993822 (Aug. 21, 2018).
Following an SEC Wells Submission, obtained “closing letter” declining to bring charges against senior executive of financial services firm, which had settled an administrative proceeding relating to mutual fund share class recommendations, Matter of SunTrust Investment Services, Inc., 2017 WL 4064192 (Sept. 14, 2017).
Represented major liquidity provider in AWC resolution of FINRA matter involving OATS reporting, and MRV resolution relating to Reg SHO issues (Oct. 17, 2017). Also represented client in cautionary letter resolution of NYSE investigation relating to maintenance of quotations (May 11, 2017).
Orally argued and briefed successful motion to dismiss federal and state RICO and common law fraud claims in Florida state court, Goldberg v. Kanegis et al., Case No. 13-22491 (Miami-Dade County Circuit Court, Complex Business Litigation Division) (Nov. 12, 2016).
Represented managing director of private equity adviser in SEC investigation and in no-admission settlement by the firm and four executives of case alleging omissions relating to conflicts of interest and payments to affiliates, Matter of Fenway Partners, LLC, 2015 WL 6689228 (Nov. 3, 2015).
As lead appellate counsel, presented oral argument and submitted briefs that persuaded the U.S. Court of Appeals for the Seventh Circuit to reverse summary judgment against investment adviser’s general counsel in the first litigated insider trading case involving fund shares, SEC v. Bauer, 723 F.3d 758 (7th Cir. 2013). On remand to the trial court, obtained summary judgment dismissing the remainder of the case, 2014 WL 4267412 (Aug. 29, 2014).
Represented executive at a major financial services firm in written and oral submissions that resulted in an SEC “closing letter” terminating investigation as to client without charges in matter involving the structuring and marketing of several collateralized debt obligation transactions, Matter of Merrill Lynch, Pierce, Fenner & Smith Inc., 2013 WL 6503674 (December 12, 2013).
Chambers USA 2020 Recognizes Firm, Lawyers
Insider Trading Investigations – Chapter 13 in Practising Law Institute’s “SEC Compliance and Enforcement Answer Book,” 2020 Edition
What Restitution Could Mean For SEC Enforcement Cases
Law 360 | (04/03/2019)
Tenth Circuit Extends SEC’s Geographic Reach. Just How Far Is Uncertain.
How Congress Could Change The Game for Digital Tokens
Law 360 | (01/10/2019)
SEC Discusses Online Trading Platforms - With a Word of Caution
Columbia Law School Blue Sky Blog | (03/29/2018)
Can The SEC Enforce Securities Laws Abroad?
Law 360 | (03/19/2018)
SEC Cautions on Trading Platforms
Revisiting Affiliated Ute: Will It Supersize Leidos?
Law 360 | (05/18/2017)
Will the Supreme Court Expand Silence as a Basis for Securities Fraud?
The CLS Blue Sky Blog | (04/04/2017)
SEC Settlements Spotlight Auditors Gone Wild
Law 360 | (10/07/2016)
Legal Antiperspirant for Audit Committee Members
New York Law Journal (Subscription Required) | (04/18/2016)
Some Insight Into SEC’s Focus On Accounting Misconduct
Law 360 | (03/15/2016)
"Insider Trading: Where Is the Line?," 2013 Columbia Business Law Review 330 (Summer 2013 Symposium Edition)
Columbia Business Law Review | (April, 2013)
New SEC Enforcement Unit Focuses on Funds and Advisers
Bloomberg BNA (Subscription Required) | (12/09/2010)
Investor Protection Provisions of the Dodd-Frank Act
Harvard Law School Forum on Corporate Governance and Financial Regulation | (07/11/2010)
“SEC Launches New Enforcement Unit to Tackle Complex Products,” Securities Regulation & Law Report (BNA), Vol. 42, No. 19, May 10, 2010
Bloomberg BNA (Subscription Required) | (05/10/2010)
Cooperation Policy Tops Changes in SEC Enforcement Manual
Bloomberg BNA (Subscription Required) | (01/25/2010)
Seminars and Presentations
PLI Hedge Fund and Private Equity Enforcement & Regulatory Developments 2019
10/01/2019 | (10/01/2019)
“SEC Litigation Trends and Practice Tips,” DC Bar
09/05/2019 | (09/06/2019)
Congressional Testimony - Putting Investors First: Examining Proposals to Strengthen Enforcement Against Securities Law Violators (House Financial Services Committee)
06/19/2019 | (06/19/2019)
PLI Hedge Fund and Private Equity Enforcement & Regulatory Developments 2018
10/09/2018 | (10/09/2018)
“Mid-Year Roundup on SEC and FINRA Enforcement Developments,” DC Bar
06/14/2018 | (06/18/2018)
PLI’s Hedge Fund and Private Equity Enforcement & Regulatory Developments 2017
11/30/2017 | (11/30/2017)
“Insider Trading & Enforcement,” Columbia Law School Conference on M&A and Corporate Governance
04/20/2017 | (04/11/2017)
"Hedge and Private Fund Enforcement & Regulatory Developments 2016", PLI program
12/01/2016 | (10/17/2016)
“Enforcement and Insider Trading”, 2016 Columbia Law School Annual Securities Regulation Conference
04/29/2016 (10:00 AM - 05:30 PM) | (04/29/2016)
“Chinese Mega-IPO Goes Public in a Globalized Capital Market,” ABA International Law Section
10/23/2015 | (10/23/2015)
"Current Issues in Securities Regulation: The Hot Topics," Symposium at Columbia Law School Center on Corporate Governance
11/21/2014 | (11/21/2014)
“SEC Enforcement’s Focus on the Asset Management Industry: Is it a New World?,” District of Columbia Bar
05/28/2014 | (05/28/2014)
“Insider Trading Update,” Alternative Investment Management Association
05/14/2014 | (05/14/2014)
"PLI Hedge Fund and Private Equity Enforcement & Regulatory Developments," Practising Law Institute
11/19/2013 | (11/19/2013)
“Leading Current Issues in Securities Regulation and Enforcement,” Symposium at Columbia Law School Center on Corporate Governance
11/15/2013 | (11/15/2013)
“SEC and FINRA Investigations of Hedge Funds, Asset Managers, Broker-Dealers and Other Investment Entities,” Securities Docket Enforcement Forum
10/09/2013 | (10/09/2013)
"SEC Enforcement: Questions for the Division Co-Director on What Lies Ahead", Federal Bar Association
06/17/2013 | (06/17/2013)
“Past, Present and Future of Insider Trading: A 50th Anniversary Re-examination of Cady, Roberts and the Revolution It Began,” Symposium at Columbia Law School Center on Corporate Governance
11/16/2012 | (11/16/2012)
FCPA Presentation at "Aftermath of the Financial Crisis" panel, ABA International Law Section
04/19/2012 | (04/19/2012)
"PCAOB Enforcement: The First 10 Years and Looking Forward," District of Columbia Bar program
03/21/2012 | (03/21/2012)
"Accountability of Independent Agencies: US and EU Experience," Maastricht University (Netherlands)
02/03/2012 | (02/03/2012)
Congressional Testimony - Fixing the Watchdog: Legislative Proposals to Improve and Enhance the SEC
Congressional Testimony - Financial Management, Work Force, and Operations at the SEC