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 two margin actions are significant. Eliminating the requirement to collect initial margin on TBA transactions will vastly simplify the implementation of the rule. Although this requirement seemed "common sense," it would have created tremendous operational problems, the difficulties and expense of which overwhelmed the benefits, which were not that great in light of the limited risks of the product.
Likewise, it is all to the good that FINRA is seeking comment on the…
Like some Cabinet newsletters, nice title, not much substance.
Improving the nuts and bolts of operations has the potential to significantly reduce systemic risk. In this regard, reducing trade date settlement from three days to two was probably as significant as anything done by Dodd-Frank (and a good bit more straightforward). Increasing the speed of cash settlement (and further reducing the speed of securities settlement) would be further significant measures to reduce systemic risk.
Commissioner Peirce has become the voice of "liberalism" (in the very, very old-fashioned sense of the word): belief in limited government, government respecting the rights and abilities of individuals to make decisions, and government agencies not stretching the bounds of their authority to accomplish what officials decide is "good policy." Note Commissioner Peirce's views (and wit) in before the Cato Institute's FinTech Unbound Conference (summarized ). At a time when so many call for the…