Profile
Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she counsels corporations, financial institutions, and individuals regarding complex investigations, litigation, and regulatory matters, including those involving the SEC, the Department of Justice, the Commodity Futures Trading Commission, and other law enforcement agencies and financial regulators.
During her eight-year tenure at the SEC, Tracy served in a variety of roles in San Francisco and Salt Lake City, most recently as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of the office’s most high-profile and impactful enforcement actions. As a former SEC trial attorney and senior counsel in the Division of Enforcement, Tracy brought several groundbreaking actions, including the SEC’s first cybersecurity disclosure enforcement action involving a public company’s failure to disclose a massive data breach and an insider trading action against a biopharmaceutical executive in the Northern District of California, identified in the media as the first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s Crypto Assets and Cyber Unit, where she co-led its Cybersecurity & Regulated Entities working group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority enforcement actions and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.
Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.
Capabilities
Experience
- Filed the SEC’s first public company cyber incident disclosure case involving a company’s failure to disclose a massive data breach perpetrated by a state actor.°
- Investigated public and private companies regarding their disclosures and internal controls and procedures concerning cybersecurity incidents, frequently in parallel with DOJ, FBI, and FTC.°
- Investigated broker-dealers, investment companies, and investment advisers concerning cyber incidents and compliance with SEC-promulgated consumer data privacy safeguards.°
- Investigated and filed what was identified as the first “shadow” insider trading case against a biopharmaceutical executive in the Northern District of California.°
- Supervised the SEC’s $413 million scienter-based fraud action in the Southern District of New York against a major European bank regarding its disclosures about its anti-money laundering compliance program. The SEC’s settlement was part of a global resolution of over $2 billion with DOJ and foreign regulators.°
- Supervised and litigated an action against dozens of individuals and entities related to the perpetration of a more than $450 million Ponzi scheme in the Las Vegas, Nevada area.
- Supervised numerous investigations concerning alleged unregistered securities offerings and alleged Ponzi schemes.°
- Supervised the SEC’s action against a major nonprofit religious organization and its investment advisor for failing to file required forms with the SEC disclosing the value of assets in its securities portfolio.°
- Investigated and filed a fraud action against an Oregon-based investment group and its top executives for concealing the firm’s troubled financial conduction from investors.°
- Conducted a nationwide investigation into broker dealers and investment advisers who placed clients’ assets into an alleged fraudulent investment.°
- In private practice prior to service at the SEC, member of a trial team representing an attorney at a large firm criminally charged with securities fraud, wire fraud, and RICO conspiracy, winning a full acquittal after a six-month federal jury trial.°
°The above representations were handled by Ms. Combs prior to her joining Greenberg Traurig, LLP.
- U.S. Securities and Exchange Commission, 2015-2024
- Regional Director, Salt Lake Regional Office, 2022-2024
- Trial Attorney, Division of Enforcement, 2021-2022
- Counsel to the SEC Director of Enforcement, 2021-2022
- Senior Counsel, Division of Enforcement, 2015-2021
- Member, Crypto Asset and Cyber Unit, 2017-2020; Co-Chair, Cybersecurity & Regulated Entities Group
Recognition & Leadership
- Listed, Utah Business Magazine, “Utah Legal Elite – White Collar & Investigations,” 2025
- Securities and Exchange Commission, Chairman’s Award for Serving the Interest of Main Street Investors, 2018 (team award)
- Securities and Exchange Commission, Director’s Awards, Division of Enforcement, 2017 and 2018
- Member, Law360 Editorial Advisory Board, Securities, 2025
Credentials
- J.D., University of Michigan Law School, 2006
- B.A., magna cum laude, Colby College, 2003
- Hon. Luis Felipe Restrepo, U.S. District Court for the Eastern District of Pennsylvania, 2007-2008
- California
- New York
- Utah
- U.S. District Court for the Central District of California
- U.S. District Court for the Eastern District of California
- U.S. District Court for the Northern District of California
- U.S. District Court for the Southern District of California
- U.S. District Court for the Eastern District of Pennsylvania
- U.S. District Court for the Southern District of New York
- U.S. Court of Appeals for the Ninth Circuit
- U.S. Court of Appeals for the Tenth Circuit