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 letter follows shortly after a report by the Bank for International Settlements essentially saying that the big tech players would become major, and very possibly dominant, participants in the national and global financial systems; and that national regulators had to focus on how best to regulate such participation. See .
This is an interesting case, particularly in light of the SEC's recent interpretation regarding the duties of an investment adviser to its client, as it is one of the few cases that turns upon the existence of a duty of care, in addition to a duty of loyalty (although both failures are alleged to be present in this case).
The objectives are a bit of a mixed bag. These are not inherently the topics that should most interest an office focused on retail investors. In practice, retail investors largely trade off of the prices that are established by more knowledgeable institutional investors. Issues as to the quality of the accounting function should not logically be the focus of the OIA. By contrast, the focus on senior investors and on broker migration makes a lot of sense.
Two very recent SEC…
The freeze on the SEC's proxy rules makes some sense from a political perspective; i.e., Rep. Waters wants to maintain the ability of holders of a small number of shares (which is not the same as a "retail investor") to create proxy fights.
However, I still do not understand the reasoning for , unless Rep. Waters thinks that it will encourage the states to go their own way on securities regulation and create a further disruption and breakdown in the (generally) unitary system of…