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
There is quite a bit here, but the following points stand out:
Mr. McKernan's criticism over the failure by regulators to make the case in support of key aspects of the Basel Endgame, and his concerns as to the damage that the requirements might do to the economy, are consistent with views expressed by many in the banking industry. His position to "end our bailout culture" and to "accept the inevitability of bank failures" is fundamental to the debate…Commissioner Uyeda has been a persistent critic of the SEC's rulemaking process under SEC Chair Gensler. (His views on process often align with those of Commissioner Hester M. Peirce.) Perhaps his most powerful statement on the subject was linked to the following news story: . But he has been consistent (see, e.g, ; ; ).
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The discussion of the margin models is in many ways similar to the debate over the uses of artificial intelligence for a number of purposes, including credit scoring. That is, the end product seems to be better, but we don't know exactly why we got that result. At least as to central clearing, this may present a practical difficulty for clearing members: How much liquidity do clearing members need to set aside to meet margin calls when the amount of the call is not readily predictable?
…These proposed rule amendments take place amid substantial changes the SEC is making in the U.S. government securities markets including proposed requirements on central clearing of certain repo and cash market transactions in U.S. Treasuries.
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