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 relief goes to the procedures associated with the custody rule (for example, the procedures to release assets from the reserve account), as opposed to the substantive requirement to segregate customer assets.
The big open question is this: what are the circumstances under which pre-trade or post-trade reporting to the public will diminish liquidity? Dealers may not want to give away their positions. Institutional customers are concerned about signaling their intent. The report does provide some discussion of these issues (see p. 12), but it does not reach any conclusions.
While the results are far too small to have any statistical validity, the Cabinet news reported a number of other instances of husbands violating their wives' confidences by trading on inside information. (See, e.g., the ""; and the ""). To date, no wives have been prosecuted for doing the same. On that note, here is .
There is little mystery as to why banks might choose to "remain silent" at this stage. They do not want to subject themselves to overtly political attacks, or be used in an obvious political stunt by Senator Warren. Senator Warren's requests for a mountain of information from these banks suggest that the information gathered to date by the CFPB is lacking and that the resolutions under the Congressional Review Act are warranted. The fact that the Senator feels it necessary to ask these…