Chief Legal Architect and a co-founder of Caffrey.AI
Steven Lofchie is the Chief Legal Architect and a co-founder of Caffrey.AI, an AI platform built for law firms, banks, and the financial regulatory industry. He is also a partner at Norton Rose Fulbright, where he advises financial institutions on securities laws, the Commodity Exchange Act, and broker-dealer regulation. Ranked by Chambers USA every year since 2007, he is the author of “Lofchie’s Guide to Broker-Dealer Regulation,” long considered the leading treatise on the subject.
Recent Articles & Comments
Although the assertion was that 70% of crypto communications are violative of FINRA Rules, FINRA also said that most of the violations were connected to a handful of firms. This suggests that the problem is at those few firms, rather than an industry issue. It is also uncertain what FINRA intends by criticizing communications that were produced or sent by affiliates of FINRA members, as those might not be subject to FINRA Rules.
This is one of a number of enforcement actions that the SEC has brought against firms that are in the business of establishing arrangements that allow them to acquire shares from small cap companies at a large discount to the market price and then flip those shares to the retail public without registration. (See, e.g., .)
A number of market participants have raised concerns that these enforcement actions extend the meaning of a "dealer" beyond the intent of the Securities…
It is instructive to read the Senators' letter in connection with , as Mr. Hsu's statement makes clear that the problems causing bank runs are complicated, that these problems are not just about "more," or stricter regulation and that the way to fix the problems is not so apparent. Beyond that, Mr. Hsu points out that one of the great fixations of the post-2008 crash interconnectedness was not relevant to recent bank failures (and thus perhaps was not that determinative in 2008 either?).…
Beyond the concerns raised about the SEC rulemaking on climate disclosure, Mr. Huizenga suggested that many of the rules adopted by the SEC in recent years likely will be vacated by court action. This seems quite likely, not only if there is a change in Administration, but also because many of these rules have been adopted by a 3-2 vote, with the dissenting Commissioners objecting both to the substance of the adopted rules and to the rulemaking process.