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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

FINRA's criticisms of the sale of "alternative" mutual funds follows up on its issuance of , which warned firms as to the sale of "complex" products (see ). This notice does not provide much in the way of detail on funds that are the subject of the story, other than that the funds do something other than own a diversified pool of common equities. Likewise, the notice does not indicate that investors were misled or that firms had some improper motive for selling the products.

Remember when GE posted increased earnings for ? That was so 20th century.

Both the number (25) and breadth (sell-side, buy-side, issuers and proprietary traders) of the associations participating in the letter to the Chair reflect very broad dissatisfaction with the SEC rulemaking process. The short time period to comment is really just one of multiple issues, and arguably not the most serious. The most problematic is the uncertainty around how the numerous different rule proposals might interact with each other. Anticipating the effect of a single major…