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Stephen J. Crimmins

Partner
+1.202.778.9440
Fax +1.202.778.9100
+1.212.536.3987
Fax +1.212.536.3901

Steve Crimmins defends clients in investigations, litigation, ADR and settlement negotiations involving the Securities and Exchange Commission and other financial services regulators. He also litigates private securities and other commercial cases, leads internal investigations, and counsels on financial regulatory matters. In addition to client representation, he chairs securities bar groups and has testified twice before Congress on SEC-related issues. He writes, speaks on professional panels, and is widely quoted on securities law topics. For the last five years he has been a member of the K&L Gates offices in both New York and Washington.

Before returning to private practice a decade ago, Steve served for eight years as a senior executive of the SEC’s Enforcement Division. He co-managed a large Trial Unit prosecuting hundreds of jury and non-jury securities cases in federal courts around the country and in SEC administrative proceedings. He also advised on SEC investigations and participated actively in SEC settlement negotiations. He previously served six years as a line SEC trial attorney and continued to litigate and try cases after his promotion to senior SEC management and the federal Senior Executive Service. A native New Yorker, he studied law at Columbia and began his litigation career at a large New York firm.

Professional Leadership

  • Chair of the Corporation, Finance and Securities Law Section, District of Columbia Bar
  • Chair of the Securities Law Section of the Federal Bar Association
  • Immediate Past Chair of the Committee on Broker-Dealer Regulation and SEC Enforcement, District of Columbia Bar
  • Editorial Advisory Board, BNA Securities Regulation & Law Report
  • “Enforcement 40” Award (recognizing top 40 securities enforcement defense lawyers nationally), Securities Docket (October 2013)
  • Recognized by “Chambers USA: America's Leading Lawyers for Business” as a “key individual” for securities regulation - enforcement
  • Recognized by “Best Lawyers in America” for securities litigation and securities regulation
  • Recognized by Washingtonian Magazine as a “top lawyer” for securities law
  • Recognized by “Washington Super Lawyers” for securities litigation

Recent Notable Matters

  • Orally argued and briefed appeal that achieved reversal of an SEC judgment against investment adviser’s senior vice president and general counsel in first litigated insider trading case involving fund shares, SEC v. Bauer, 723 F.3d 758 (7th Cir. 2013)
  • Obtained closing letter terminating SEC investigation as to executive at major financial services firm in matter involving structuring and sale of CDOs (December 2013)
  • Obtained closing letter terminating SEC investigation relating to short selling (December 2013)
  • Achieved successful settlement on the eve of trial in an SEC valuation case involving Morgan Keegan outside directors, Matter of Alderman, SEC Rel. IC-30557 (June 2013)
  • Obtained decision broadly extending Janus limitation on “statement” liability to all branches of the ’33 and ’34 Act antifraud provisions, SEC v. Kelly, 817 F. Supp. 2d 340 (S.D.N.Y. 2011)
  • Through ADR achieved resolution of two substantial commercial disputes for related clients (November 2012 and January 2013) 

Congressional Testimony

  • Testified before Congress at hearing on “Fixing the Watchdog: Legislative Proposals to Improve and Enhance the SEC,” House of Representatives Committee on Financial Services, September 15, 2011
  • Testified before Congress at joint hearing on “Financial Management, Work Force, and Operations at the SEC,” Subcommittees of the House of Representatives Committee on Oversight and Government Reform, March 10, 2011

Selected Speaking Engagements

  • "The SEC Enforcement Division's Renewed Interest in Structured Products," K&L Gates webinar, June 20, 2014
  • “SEC Enforcement’s Focus on the Asset Management Industry: Is it a New World?,” Federal Bar Association and DC Bar joint program, Washington, May 28, 2014 (presented with Chief of SEC Enforcement’s Asset Management Unit)
  • “Insider Trading Update,” Alternative Investment Management Association, New York, May 14, 2014 (presented with Deputy Chief of SEC Enforcement’s Market Abuse Unit)
  • "PLI Hedge Fund and Private Equity Enforcement & Regulatory Developments," Practising Law Institute, New York, November 19, 2013
  • “Leading Current Issues in Securities Regulation and Enforcement,” Symposium at Columbia Law School Center on Corporate Governance, New York, November 15, 2013
  • “SEC and FINRA Investigations of Hedge Funds, Asset Managers, Broker-Dealers and Other Investment Entities,” Securities Docket Enforcement Forum, Washington, October 9, 2013
  • "SEC Enforcement: Questions for the Division Co-Director on What Lies Ahead" (chaired panel with SEC Enforcement Director), Federal Bar Association, June 17, 2013
  • "Hedge Fund Enforcement & Regulatory Developments," Practising Law Institute, New York, March 6, 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, New York, November 16, 2012
  • FCPA Presentation at "Aftermath of the Financial Crisis" panel, ABA International Law Section, New York, April 19, 2012
  • "PCAOB Enforcement: The First 10 Years and Looking Forward," DC Bar, March 21, 2012
  • "Accountability of Independent Agencies: US and EU Experience," Maastricht University (Netherlands), February 3, 2012
  • “SEC Enforcement’s New Asset Management Unit – Fresh Focus on Advisers and Funds” (chaired panel with Unit leaders), New York City Bar Association, November 23, 2010
  • “Impact of Dodd-Frank on SEC Enforcement,” New York City Bar Association, Sept. 26, 2010
  • “Riding Herd on Complex Products – SEC Enforcement Launches Its Structured and New Products Unit” (chaired panel with Unit leaders), New York City Bar Association, April 26, 2010
  • “The SEC’s New Cooperation Policy: What You Need to Know to Navigate the New Guidelines” (chaired panel with SEC enforcement deputy director), New York City Bar Association, February 23, 2010

Selected Publications

  • "Insider Trading: Where Is the Line?," 2013 Columbia Business Law Review 330 (Summer 2013 Symposium Edition)
  • “New SEC Enforcement Unit Focuses on Funds and Advisers,” Securities Regulation & Law Report (BNA), Vol. 42, No. 47, December 6, 2010
  • “Is SEC Scrutiny of Instant Messages on the Rise?” Ignites, October 5, 2010
  • “Investor Protection Provisions of the Dodd-Frank Act,” Harvard Law School Forum on Corporate Governance and Financial Regulation, July 11, 2010
  • “SEC Launches New Enforcement Unit to Tackle Complex Products,” Securities Regulation & Law Report (BNA), Vol. 42, No. 19, May 10, 2010
  • “Cooperation Policy Tops Changes in SEC Enforcement Manual,” Securities Regulation & Law Report (BNA), Vol. 42, No. 4, January 25, 2010
  • “Securities Regulation Under the Obama Plan,” Securities Regulation & Law Report (BNA), Vol. 41, No. 26, June 29, 2009
  • “The SEC's Blueprint to Reinvigorate Enforcement,” Securities Regulation & Law Report (BNA), Vol. 41, No. 15, April 13, 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
  • 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
  • “Where Are We Going With SEC Officer and Director Bars?” Securities Regulation & Law Report (BNA), Vol. 38, No. 17, April 24, 2006