Matthew Comstock
Partner, Asset Management
Matthew Comstock is a partner in Willkie’s Asset Management Department, where he is a part of the Regulatory and Enforcement, and Willkie Digital Works practices. He is based in the Firm’s Washington, DC office.
With over two decades of experience at the SEC and in private practice, Matt has a diverse practice spanning the legal and regulatory aspects of broker-dealer, securities trading and markets businesses, including digital asset regulation.
He advises trading platforms, broker-dealers, clearing agencies, private funds and other clients on a variety of compliance, regulatory and transactional matters. He has substantial experience in broker-dealer financial responsibility and 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. Matt regularly assists clients in the creation of trading platforms, custody and trading of alternative investments and digital assets, and navigating the regulatory requirements facing broker-dealers. He has a particular focus on regulation of digital assets issued on the blockchain, and has advised on the creation of a digital markets trading platform and establishment of cryptocurrency trading desks.
With over two decades of experience at the SEC and in private practice, Matt has a diverse practice spanning the legal and regulatory aspects of broker-dealer, securities trading and markets businesses, including digital asset regulation.
He advises trading platforms, broker-dealers, clearing agencies, private funds and other clients on a variety of compliance, regulatory and transactional matters. He has substantial experience in broker-dealer financial responsibility and 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. Matt regularly assists clients in the creation of trading platforms, custody and trading of alternative investments and digital assets, and navigating the regulatory requirements facing broker-dealers. He has a particular focus on regulation of digital assets issued on the blockchain, and has advised on the creation of a digital markets trading platform and establishment of cryptocurrency trading desks.
Experience
Matt was most recently a partner at Davis Wright Tremaine LLP, and before that, a shareholder at McGonigle, P.C., before the firms combined. Earlier in his career, he served in the SEC's Division of Trading and Markets in the positions of branch chief, special counsel and staff attorney in the Office of Financial Responsibility. While there, Matt handled a variety of matters relating to broker-dealer net capital requirements, customer protection, broker-dealer books and records requirements, and broker-dealer liquidations.
- Named as one of "America's Leading Lawyers for Business" by Chambers USA in Financial Services Regulation: Broker Dealer (Compliance) (Nationwide), 2020-2021, 2023
- Co-Author, “Digital Asset Regulation in the United States: An Opportunity for Progress or a Threat to Innovation?,” The US-Israel Legal Review 2021
- Author, “Crypto Status Remains Unclear Despite SEC Assurance,” Law360, 8/26/21
- Panelist, "SEC's Proposed Safeguarding Rule: Implications for Investment Advisers, Broker-Dealers, and Digital Assets," D.C. Bar, 6/5/23
- Panelist, "Key Legal and Regulatory Issues for Private Client Firms," SIFMA's C&L Annual Seminar, San Diego, 3/14/23
- Moderator, "Trading and Custody of Digital Securities and Closing Remarks," CryptoLex 2021, 1/12/21
Credentials
Education
University of Augsburg, LL.M., 1995 University of Pittsburgh School of Law, J.D., 1994 University of Pittsburgh, Katz Graduate School of Business, M.B.A., 1994 University of Pittsburgh, B.A., 1991