Overview
Coy Garrison, a former SEC counsel and career staffer, is a partner in Steptoe's Government Affairs & Public Policy practice and the Financial Innovation & Regulation practices. Coy advises private fintech companies, public companies, and financial institutions on how to navigate challenging legal and regulatory issues related to crypto and blockchain technology. He also advises public companies on disclosure, securities law compliance, governance, sustainability, cybersecurity risk management and incident disclosure, and general corporate law matters.
Blockchain and Cryptocurrency
Drawing on more than eight years of experience at the SEC and his technical understanding of federal securities laws, he provides regulatory counsel to help crypto clients meet their legal obligations, manage risk, and achieve their business goals.
Coy also blends his public policy experience with his granular knowledge of the securities laws to guide clients in legislative and regulatory advocacy before Congress, federal financial regulators, and self-regulatory organizations. He provides tailored analyses of how proposed legislation and financial regulations would impact clients in this fast-evolving industry.
A trusted thought leader in the industry, Coy has testified before Congress on crypto market structure issues and the scope of federal securities laws. He provides strategic advice to clients facing issues before the House Financial Services Committee, Senate Banking Committee, and both Agriculture Committees.
Prior to joining Steptoe, Coy served as counsel to SEC Commissioner Hester Peirce and to former Director of the SEC's Division of Corporation Finance, Bill Hinman. As Commissioner Peirce's lead advisor on crypto matters, Coy counseled her on SEC crypto enforcement matters, was responsible for crafting crypto policy positions, including composing token sale safe harbor proposals. As counsel to the Division of Corporation Finance Director, Coy coordinated and advised on reviews of registration statements for crypto exchange-traded products and token offerings, represented the Commission on the FSOC's Digital Assets Working Group, and worked closely with the director of FinHub on a variety of matters.
Financial Services
Coy's financial services practice involves counseling public companies and their boards on SEC reporting and disclosure requirements, proxy matters, and shareholder proposals. His representation focuses on newly public companies, emerging growth companies, and foreign private issuers that are seeking practical and sound advice.
Coy helps clients resolve novel and complex securities law issues and navigate bureaucracies at the SEC and other federal and state financial regulators. Coy also advises clients seeking to balance new ESG disclosure obligations with competing political pressures.
He guides trade associations, SEC registrants, and public companies in their policy advocacy before Congress, the SEC, and other federal financial regulators.
Coy brings fresh insights to clients based on his years of service at the SEC. As counsel to the Commissioner, he advised on major rulemakings relating to public company disclosure and capital formation, including on cybersecurity and climate-related information. Coy also previously served as special counsel in the SEC's Office of Real Estate and Commodities, where he led the agency’s disclosure review program for the non-listed REIT industry. Coy started his career at the SEC as an attorney-adviser in the Office of Real Estate and Commodities and also served as a reviewer on the SEC’s Shareholder Proposal Task Force.
- District of Columbia
- Maryland
- US Court of Appeals, Fourth Circuit
- Certificate in Securities and Financial Regulation, Georgetown University Law Center, 2016
- J.D., Pepperdine University School of Law, 2012, magna cum laude; Associate Editor, Pepperdine Law Review
- B.A., University of Maryland, 2008, Phi Beta Kappa
Areas of Work
Representative Matters
- Advise foundation for a Layer 1 protocol on US legal and regulatory matters, treasury management activities, and governance decisions.
- Provide actionable, customized guidance on US securities law compliance measures to decentralized exchange protocol developers, NFT marketplace, wallet provider, and software development companies.
- Advise emerging growth company on SEC disclosure and compliance issues.
- Advise token issuers identified in SEC enforcement actions against crypto exchanges.
- Provide tailored analysis of proposed legislation and SEC regulations to large crypto-focused venture capital firm.
- Advise public crypto company on SEC disclosure, public policy, and government relations matters.
- Counsel the board of directors of a public company on strategic decisions and general corporate law matters.
- Counselled a digital asset creation platform on the minting of tokens in a compliant manner under US securities laws.
- Provided regulatory counsel to a UK cryptoasset registered company entering the U.S. market.
- Advised digital asset wallet company on money transmitter compliance and associated public policy messaging.
- Represented crypto companies responding to SEC subpoenas.
- Provided fintech firms with regulatory counselling for product launches and led engagement with SEC.
- Provided cybersecurity incident response counselling to a public company.
- Advised an SEC registrant on risk associated with current ESG reporting and disclosures.
- Counselled foreign financial institutions on compliance with SEC regulations.
- Advised a corporate insider on launching a proxy contest and corporate governance matters.
- Advised corporate insiders on Section 13 and Section 16 reporting obligations.
Speaking Engagements
- Introduction speaker, "Fireside Chat with Commissioner Hester Peirce," Fordham Law Blockchain Regulatory Symposium, October 7, 2024
- "Fin Tech Litigation," LexMundi Litigation, Arbitration, and Dispute Resolution North America Practice Group Conference, November 10, 2023
- "SEC Climate Disclosure and The Major Questions Doctrine," Symposium Hosted By Fordham Journal of Corporate & Financial Law, October 27, 2023
- "The Novel Chances of Regulating DeFi," State of Crypto: Policy and Regulation, October 24, 2023
- "Evolving Ecosystem: Market Integrity," Fordham Law Blockchain Regulatory Symposium, October 2, 2023
- "SEC Rulemaking and Enforcement Trends in 2023," Webinar Hosted By Professional Liability Underwriting Society, September 27, 2023
- "Dimensions of DeFi,” Meridian Conference, September 26, 2023
- "The Future of Digital Assets: Providing Clarity for the Digital Asset Ecosystem," Testimony Before the U.S. House of Representatives Committee on Financial Services, June 13, 2023
- "The Race to Crypto Regulation," Webinar Hosted By Bakkt, May 10, 2023
- "The SEC’s Activist Agenda," ABA Business Law Section Spring Meeting, April 27, 2023
- "Crypto Regulatory Q&A for Founders," Keiretsu at Consensus 2023, April 27, 2023
- "ESG and Climate Disclosure," Steptoe Food Contact Conference, April 26, 2023
- "US Status on Crypto-Regulation," Cornell Blockchain Conference, April 21, 2023
- "Navigating the Global Regulatory Landscape for DeFi," Webinar Hosted by Merkle Science, April 18, 2023
- "FinTech Regulation," The Federal Reserve Bank of San Francisco Conference on FinTech: Innovation, Inclusion, and Risks, February 24, 2023
- “ESG and PFAS: Corporate Compliance and Counseling on Rapidly Evolving Issues,” State Bar of Georgia Corporate Counsel Institute, December 15, 2022
- “We Won’t Get Fooled Again: Where Crypto Goes From Here,” Decipher Conference, December 6, 2022
- “The Future of Crypto Under Biden’s Administration,” NYU School of Law, November 14, 2022
- Moderator, “Trends and Developments in the Cybersecurity and Insider Threat Landscape,” Women’s White Collar Defense Association, October 19, 2022
- "Emerging Issues in Sustainability", The Food Industry Association, October 18, 2022
- “Alphabet Soup and Interagency Cooperation,” Fordham Law Blockchain Regulatory Symposium, October 3, 2022
News & Publications
Blockchain Blog
SEC Articulates Standards for Non-Security Stablecoin, Providing Clarity for Issuers
April 15, 2025
Press Releases
April 9, 2025
Media Mentions
March 28, 2025
Media Mentions
WIRED Quotes Coy Garrison in Article on SEC's Reversal of Crypto Lawsuits
February 28, 2025
Press Releases
Coy Garrison Provides Testimony on Digital Asset Regulation to House Committee on Financial Services
February 11, 2025
Client Alerts
January 17, 2025
By: Evan T. Abrams, Tarrian L. Ellis, Christopher R. Fredrich, Coy Garrison, Andrew Owens, Benjamin M. Saul
Blockchain Blog
Crypto Wine and Ill-Fitting Regulatory Bottles:
January 16, 2025
By: Michelle Kallen, Coy Garrison, Nathaniel Sans
Stepwise Risk Outlook
Cryptocurrency at a Crossroads: Prospects and Risks for Businesses
January 9, 2025
Media Mentions
The Financial Times Quotes Coy Garrison on Impact the President-Elect Might Have on Crypto Space
January 2, 2025
Resources
Events
Webinars
Quarterly Investigations & Enforcement Update
July 31, 2024
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao
Seminars & Events
Complimentary Food Contact Conference
April 25, 2023 - April 26, 2023
Speakers: Joan Baughan, Daniel C. Rubenstein, Joseph Dages, Carly Rolph, Kimberly Cassidy, Ph.D., Jessica Cooper, Ph.D., Patricia Kinne, Glen Rosini, Tom Gillett, Anthony G. Hopp, Ruxandra Cana, Coy Garrison, Abigail Miller, Regulatory Review Chemist, US Food and Drug Administration (FDA), Sean Fischer, Consumer Safety Officer, US Food and Drug Administration (FDA), Daniel Felton, Executive Director, AMERIPEN
Webinars
Investigations & Enforcement Webinar Series
January 26, 2023
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Coy Garrison, Patrick F. Linehan, Zoe Osborne, Wendy Wysong
Webinars
Investigations and Enforcement Webinar Series
October 27, 2022
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, Patrick F. Linehan, Michael Campion Miller, Jason M. Weinstein, Charles Whiddington, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 28, 2022
Speakers: Jason Abel, Iris E. Bennett, Amba M. Datta, Coy Garrison, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Previous Employment
- Counsel, Office of Commissioner Hester M. Peirce, US Securities and Exchange Commission (2019-2022)
- Senior Special Counsel, Office of Director of Division of Corporation Finance, US Securities and Exchange Commission (2018-2019)
- Special Counsel, Office of Real Estate and Commodities, US Securities and Exchange Commission (2016-2018)
- Attorney-Advisor, Office of Real Estate and Commodities, US Securities and Exchange Commission (2013-2016)
- Staff Attorney, US Court of Appeals for the Fourth Circuit (2012-2013)
Professional Affiliations
- Chair of SEC Subcommittee, American Bar Association Business Law Section's Corporate Governance Committee