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
Are the investors who make investment decisions based on celebrity status reading OIEA guidance? If they are not, this is not the best way to reach those investors. What is needed is something more akin to .
Both of these rules were viewed as discouraging fiduciaries from taking ESG considerations into account in investing and in voting shares, respectively. There is little doubt that the DOL will revise both rules.
There is not that much variance between the SEC's 2006 statement on the justification for penalties and the position of Commissioner Crenshaw. The factors that Commissioner Crenshaw cites as significant to the determination of penalties are generally consistent with not only the 2006 statement but also with other statements by the SEC, particularly as to the significance of factors such as cooperation.
Ms. Crenshaw seems to part ways with the 2006 statement in distinguishing between…
The run-up in GameStop stock should not be used as a pretext to further legislation or rulemaking that does little to help retail investors or that may even injure them. (See Cadwalader Memorandum, ".") While it may be a legislator's first instinct, new rules are usually not the solution to a high-profile event. More importantly, they often lead to unwanted consequences. For example, regulations governing investment research and the adoption of Regulation Best Interest intended to help…