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
This is actually quite a significant targeted exam letter. It has relevance well beyond those firms that have a zero commission offering. FINRA is asking very detailed questions about how the firm makes money, and how the firm's revenue stream affects the manner in which the firm does business and treats customers.
The type of information that the letter is intended to elicit includes information that would be relevant to the completion of Form CRS that is to be provided to clients.…
Professor Michael Kearns raises important moral, philosophical and economic dilemmas to be considered when designing AI systems to achieve "equitable" outcomes:
Stakeholders must decide what is the right accuracy-fairness balance. We must also be cognizant of the fact that different notions of fairness may be in competition with each other as well. For example, it is entirely possible that by asking for more fairness by race, we must suffer less fairness by gender. These are painful but…The revisions are materially more of the same. There are a lot of requirements. There is also a good deal of specificity as to what is required. For many businesses, strict compliance with the requirements will be costly and difficult to achieve.
Further, the amount of time that the California AG allowed for public comment on the revisions (approximately two weeks) is unduly short. Given the scope/complexity/costs of these regulations, denying a reasonable timeframe to understand…
The reaction to Facebook's announcement of Libra was, to put it mildly, negative from all hands. The story, published last July is illustrative of:
the increasing concerns over the uses of data by Big Tech; see also , and hostility by members of Congress to Facebook in particular; see also .The announcement of Libra and the ruckus that followed also illustrated the technology company's lack of sophistication as to the details of financial regulation. Had Facebook chosen to market…