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 SEC and FINRA will have to provide guidance as to how 24-hour trading will impact other regulatory requirements such as the timing of margin calls, or the calculation of segregation requirements.
It is an open question as to how aggressive the SEC will be in allowing the exchanges to engage with publicly traded products, such as highly leveraged ETFs.
4X is serious leverage for a publicly traded product. It's not hard to imagine the regulators feeling some discomfort with it. It will be interesting to see where the SEC comes out, both as to the potential for fraud and as to the public interest.
One would expect to see all of the listing exchanges give themselves similar discretion, if they do not already have it. It is to be expected that the exchanges will start to take a much harder look at issuers whose assets are largely outside the United States and that do not have a significant prior trading history on a major non-U.S. exchange.