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
Ms. Liang might want to consider the following:
While it is obvious that the banks that failed did a poor job of managing interest rate risk, the precipitant of that failure was high and rapid inflation; banks borrow short and lend long; one can reasonably guess that there are widespread losses from inflation throughout the banking system, even if other banks have not failed. Blaming the banks' failures on "social media" seems to be an assertion making the rounds; but in the 2008…While this would seem to be the SEC setting a bad example on all three scores, the refusal to produce records as to proposed climate change regulations is the most troublesome. If adopted, the regulations would impact every SEC-registered issuer and would be materially expensive to implement. Accordingly, it is hard to imagine any justification for being less than fully transparent with Congress on the proposed regulations.
Mr. Massad's proposal appears consistent with our recent proposal to allow digital asset market participants to decide whether they preferred to be regulated by the SEC or the CFTC. The desire of each regulator to be the favored choice would motivate both regulators to put forward a workable system of rules. See .
It is not at all obvious that the additional regulations that Chair Gensler seeks to impose will improve the markets for U.S. Government Securities. What would seem obvious is that the regulations will impose meaningful additional costs on participants in the market, at a time when the federal deficit is soaring. In short, if the cost of trading in U.S. Government Securities goes up, that increase in cost will be borne by taxpayers whose tax dollars go to pay interest on the debt.