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 there are material questions as to whether Nasdaq's proposal is consistent with the Exchange Act, no one really has an incentive to challenge the proposal in court. Issuers that believe Nasdaq's rulemaking is inappropriate will simply list elsewhere.
Given that the firm clearly violated Regulation SCI, there is simply no need for FINRA to throw in a charge of a violation of FINRA Rule 2010. It has already reached the point that every violation of any FINRA Rule is also a violation of Rule 2010; now is it going to be the case that any violation of an SEC Rule also violates Rule 2010?
Historically, the purpose of Rule 2010 (or its predecessor) was to allow FINRA to charge essentially an ethical violation even when it was not clear…
At the forum, Chair Gensler advanced his interest in comprehensive SEC regulation of cryptocurrencies and digital assets. This regulatory philosophy is largely consistent with both his tenure as Chair of the CFTC and .
One can be sympathetic to the concerns raised by Mr. Gensler and Ms. Warren, but also believe that applying the full burdens of securities regulation to digital assets will stifle innovation. Put differently, there may be ways to regulate offerings of digital assets,…
See also , which is intended to put additional regulatory constraints on firms that employ a significant number of individuals with checkered pasts.