Home



Printable Version
Stephen J. Crimmins  Partner
Washington DC  +1.202.778.9440
New York  +1.212.536.3987
Fax +1.202.778.9100
Fax +1.212.536.3901
stephen.crimmins@klgates.com Add to Outlook Contacts


Areas of Practice Professional Background Professional/Civic Activities Speaking Engagements Court Admissions Bar Admissions Education

Areas of Practice

Steve Crimmins represents clients in enforcement investigations and litigation conducted by the Securities and Exchange Commission and other financial services regulators, as well as in private securities litigation. He also leads internal investigations and counsels on regulatory compliance, corporate governance and other SEC-related issues.

Professional Background

Steve practiced with the SEC for 14 years, eight of which were in senior management. As the Deputy Chief Litigation Counsel of the SEC’s Enforcement Division in Washington, D.C. from 1993 until 2001, he was one of 11 members of the Senior Executive Service at division headquarters. Steve co-managed a unit of 25 first-chair trial attorneys representing the SEC in hundreds of securities cases in the federal courts and in administrative proceedings. He also consulted on SEC investigations, participated actively in settlement negotiations, and served as an adviser to attorneys in SEC regional offices. Steve joined the SEC as a trial attorney in 1987 and continued to litigate and try cases for the agency after his promotion to senior management in 1993. He began his career at a large New York law firm.

Since returning to the private sector in 2001, Steve has successfully represented public companies, directors, senior corporate officers, financial services firms and their professionals, Big Four accountants and others in a wide range of securities cases. These have included SEC matters charging financial reporting violations, insider trading, market manipulation, and violations of rules governing broker-dealers, investment advisers and investment companies. On multiple occasions he has obtained SEC “termination letters” closing investigations as to clients without enforcement action following Wells notices.

Since 2006, Steve has been selected annually by peers for inclusion in "The Best Lawyers in America" in the area of securities law. He has also been selected as a "Washington, D.C. Super Lawyer" in the area of securities litigation.

Steve is regularly quoted by the national news media, speaks on SEC-related professional panels, and has published numerous articles on securities litigation. Recent articles have focused on the SEC's new cooperation policy and changes to its enforcement manual, the Obama Administration’s proposals to reform securities regulation, what to expect from a “reinvigorated” SEC, how the SEC is responding to subprime and credit crisis issues, the option backdating initiative, and cross-border securities enforcement.

Professional/Civic Activities
  • Chair, Executive Council of Securities Law Committee, Federal Bar Association
  • Vice Chair, Broker-Dealer and SEC Enforcement Committee, District of Columbia Bar Association
  • Member, Editorial Advisory Board, BNA Securities Regulation & Law Report

Speaking Engagements
  • "Riding Herd on Complex Products - SEC Enforcement Launches Its Structured and New Products Unit" (panel with Structured Products Unit leaders Kenneth Lench and Reid Muoio), New York City Bar Association and DC Bar joint program, April 26, 2010
  • "The SEC's New Cooperation Policy: What You Need to Know to Navigate the New Guidelines" (panel with SEC Deputy Director Lorin Reisner), New York City Bar Association and DC Bar joint program, February 23, 2010
  • "SEC Enforcement Initiatives: What the Changes Mean for Counsel and their Clients" (panel with SEC New York Regional Director George Canellos), BNA Audioconferences, September 23, 2009
  • “SEC Commissioners Aguilar and Campos Speak on SEC Enforcement Trends and Priorities” (moderator), Committee on Broker-Dealer Regulation and SEC Enforcement, District of Columbia Bar, March 18, 2009
  • “Defending Securities Investigations: Documents and Testimony” (panelist), Corporation, Finance and Securities Law Section, District of Columbia Bar, February 25, 2009
  • “FSA Investigations and Enforcement 2008” (panelist), City & Financial Conferences, London, December 3, 2008
  • “The SEC's New Enforcement Manual: What You Need to Know” (moderator), November 5, 2008
  • “Perspectives on Enforcement: A Conversation With SEC Commissioner Atkins” (moderator), Committee on Broker-Dealer Regulation and SEC Enforcement, District of Columbia Bar, October 28, 2008
Publications 
  • "Investor Protection Provisions of the Dodd-Frank Act," published on the Harvard Law School Forum on Corporate Governance and Financial Regulation, July 11, 2010, available at http://blogs.law.harvard.edu/corpgov/.
  • "SEC Launches New Enforcement Unit to Tackle Complex Products," Securities Regulation & Law Report (BNA), Vol. 42, No. 19, May 10, 2010. Republished in World Series Law Report (BNA International), Vol. 16, No. 6, June 2010
  • "Cooperation Policy Tops Changes in SEC Enforcement Manual," Securities Regulation & Law Report (BNA), Vol. 42, No. 4, January 25, 2010. Republished in United States Law Week (BNA), Vol. 78, No. 28, February 2, 2010, and in Corporate Counsel Weekly (BNA), Vol. 25, No. 5, February 3, 2010
  • "Securities Regulation Under the Obama Plan," Securities Regulation & Law Report (BNA), Vol. 41, No. 26, June 29, 2009. Republished in World Series Law Report (BNA International), Vol. 15, No. 7, July 2009
  • “The SEC's Blueprint to Reinvigorate Enforcement,” Securities Regulation & Law Report (BNA), Vol. 41, No. 15, April 13, 2009. Republished in Corporate Counsel Weekly (BNA), Vol. 24, No. 136, April 29, 2009, and in World Series Law Report (BNA International), Vol. 15, No. 5, May 2009 
  • “A Reinvigorated SEC - Subprime, Insider Trading and Ponzi-type Frauds Are on the Table,” New York Law Journal, February 9, 2009
  • Chapter 4, “Government Enforcement Response,” in Credit Market and Subprime Distress: Responding to Legal Issues (PLI), (2008)
  • “What’s Important in the SEC’s New Enforcement Manual,” Securities Regulation & Law Report (BNA), Vol. 40, No. 41, October 20, 2008. Republished in abridged form in Corporate Counsel Weekly (BNA), Vol. 23, No. 42, October 29, 2008, and in World Series Law Report (BNA International), Vol. 14, No. 11, Nov. 2008
  • Chapter 12, “Defending an SEC Investigation,” in Securities Investigations – Internal, Civil and Criminal (PLI) (2008)
  • “Subprime Securities Litigation: Three Threshold Legal Issues,” Securities Regulation & Law Report (BNA), Vol. 39, No. 49, December 24, 2007
  • “Subprime Mortgage Lending: Possible Securities Litigation Exposure,”  Securities Regulation & Law Report (BNA), Vol. 39, No. 37, September 24, 2007
  • “A New Age Dawns - International Enforcement Becoming More Cooperative and Similar to the SEC Model,” International Financial Law Review ( London), February 2007
  • “Sorting Out the Option Backdating Cases,”  Securities Regulation & Law Report (BNA), Vol. 38, No. 46, November 20, 2006. Republished in World Securities Law Report (BNA International), Vol. 12, No. 12, Dec. 2006, in White Collar Crime Report (BNA), Vol. 1, No. 25, January 5, 2007, and in abridged form in Corporate Counsel Weekly (BNA), Vol. 21, No. 46, November 29, 2006
  • “Where Are We Going With SEC Officer and Director Bars?”  Securities Regulation & Law Report (BNA), Vol. 38, No. 17, April 24, 2006. Republished in World Securities Law Report (BNA International), Vol. 12, No. 5, May 2006, and in abridged form in Corporate Counsel Weekly (BNA), Vol. 21, No. 21, May 24, 2006
  • “Will NASD’s New TCDO Power Put Its Enforcement Cases on a Fast Track?”  Securities Regulation & Law Report (BNA), Vol. 36, No. 34, August 23, 2004
  • “The Mutual Fund Crisis: Beginning to See a Resolution,”  Securities Regulation & Law Report (BNA), Vol. 36, No. 8, February 23, 2004
  • “Plain English Guidebook to SEC Recordkeeping and Retention,” CCH Incorporated, 2003
  • “The Mutual Fund Probe: What We Can Tell So Far?”  Securities Regulation & Law Report (BNA), Vol. 35, No. 34, November 3, 2003
  • “New Administrative Proceeding Rules Create Timing Concerns for Defense Counsel,”  Securities Regulation & Law Report (BNA), Vol. 35, No. 8, February 24, 2003
  • “Sweeping Securities Law Reform Will Affect Issuers, Officers and Directors,”  The Legal Intelligencer (Philadelphia), August 12, 2002
  • “New SEC Certification Requirements Demand Immediate Attention by CEOs and CFOs,” Securities Regulation & Law Report (BNA), Vol. 34, No. 27, July 8, 2002
  • “SEC Resolves Long-Standing Questions About Its Cease-and-Desist Remedy,”  Securities Regulation & Law Report (BNA), Vol. 33, No. 29, July 23, 2001

Court Admissions
  • U.S. Supreme Court
  • U.S. Court of Appeals for the First Circuit
  • U.S. Court of Appeals for the Second Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Eleventh Circuit
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. District Court for the District of Columbia
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the Eastern District of New York
  • U.S. District Court for the District of Massachusetts
  • U.S. District Court for the District of Connecticut
  • U.S. District Court for the Northern District of Illinois
  • U.S. District Court for the Southern District of Texas
  • U.S. Court of International Trade

Bar Admissions
  • Bar of District of Columbia
  • Bar of Massachusetts
  • Bar of New York
Education
  • J.D., Columbia University School of Law (Articles Editor, Columbia Journal of Law & Social Problems)
  • B.A., Fordham University

PRACTICES & INDUSTRIES
Broker-Dealer
Class Action Litigation Defense
Foreign Corrupt Practices Act (FCPA)
Global Government Solutions
Government Enforcement
Investment Management, Hedge Funds and Alternative Investments
Newsstand
Global Financial Market Watch Blog