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 OCC's laundry list of considerations on system, process, and technological changes needed for the T+1 transition was prepared for national banks, it is useful for firms of all types, including broker-dealers and buy-side firms.
It would be interesting to know how the CFPB determined that $3 could be an acceptable fee amount. Such a fee would require an assumption that no time of a bank employee is spent on overdrafts or else that the fee amount is not expected to cover the bank's costs.
Will the end result of the rule proposal be to hit bank pocketbooks and benefit consumers (as the CFPB Director contends), or will the result be that banks are less willing to carry accounts that become subject to…
Following disclosure of the hack, House Financial Services Committee Chair Patrick McHenry wrote a letter to the SEC demanding an explanation for the breach. Directing his admonition to Chair Gensler, Mr. McHenry stated that "[t]his failure is unacceptable, and it is disturbing that your agency could not even meet the standard you require of private industry."
It is notable that in the SEC's response, Chair Gensler did not concede that additional security measures were necessary,…
What I found most interesting about the report is the extent to which younger and lower-asset investors were relying on social media for investment information, rather than on broker-dealers or investment advisers This is certainly not entirely surprising. Large numbers of younger investors do not have wealth that would make them attractive clients for investment advisers charging based on assets under management.
The fact that such investors do not obtain information from…