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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.