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
The decision to redo the various forms intended to collect systemic risk data is completely sensible and seemingly overdue. (As , Form PF and its various spin-offs are worthless.) That said, now is not the time for the redo. Rather than adopt a rule change during a period when no one in the industry is likely to have an ability to focus on the details, which are important, this should be put on hold. Better to spend another year collecting useless data than to make revisions that don't…
One common theme that runs through the report: "Respondents have indicated that there are impediments to the development of sustainable finance, such as the lack of reliable and credible data and the lack of standards to promote comparability between sustainable investments" (at page 23). If there is some more limited, specific, and definable objective that IOSCO believes can improve disclosure standards, then IOSCO should specify and define it. Otherwise, "sustainable finance" remains too…
If the CFTC is going to extend comment periods, why not a month, or two months? Why two days? Of all the extensions granted during the pandemic, this must be the shortest.
Excerpt from Swann's Way, Remembrance of Things Past, Volume One, Marcel Proust (1871–1922): "The hour when an invalid, who has been obliged to start on a journey and to sleep in a strange hotel, awakens in a moment of illness and sees with glad relief a streak of daylight shewing under his bedroom door. Oh, joy of joys! it is morning. The servants will be about in a minute: he can ring, and some one will come to look after him. The thought of being made comfortable gives him strength to…