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 a good letter. There has been an unfortunate recent legislative and regulatory tendency to push responsibility up to an entity's board of directors, or chief executive officer, even where the matter did not require such high-level attention. Elevating matters inappropriately just detracts from the ability of senior management to do their real jobs. This letter is a good step in the opposite direction by allowing an appropriate delegation of responsibility.
This is a good letter. There has been an unfortunate recent legislative and regulatory tendency to push responsibility up to an entity's board of directors, or chief executive officer, even where the matter did not require such high-level attention. Elevating matters inappropriately just detracts from the ability of senior management to do their real jobs. This letter is a good step in the opposite direction by allowing an appropriate delegation of responsibility.
Chair Giancarlo explained that his predecessor had taken a very aggressive stance as to the scope of U.S. regulation. Former Chair Gensler effectively asserted that the Europeans would have to implicitly consent to complying with CFTC regulations if they wanted to do any business involving U.S. businesses or markets. The Europeans appropriately, and successfully, pushed back on this proposition.
When Mr. Giancarlo assumed the role of CFTC Chair, he completely, and…
Chair Giancarlo explained that his predecessor had taken a very aggressive stance as to the scope of U.S. regulation. Former Chair Gensler effectively asserted that the Europeans would have to implicitly consent to complying with CFTC regulations if they wanted to do any business involving U.S. businesses or markets. The Europeans appropriately, and successfully, pushed back on this proposition.
When Mr. Giancarlo assumed the role of CFTC Chair, he completely, and…