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
By saying that banks have a high level of "compliance risk," the regulators are, in effect, saying that the government regulations are, themselves, a material threat to the financial system. One interpretation derived from the report is that banks must get serious about following regulation. Another interpretation may be that regulatory enforcement and penalties have become so severe that the government itself has become a threat to financial stability. Either way, there is not much to boast…
Some of the most unfortunate incidents that occurred during Chair White's tenure were the recurrent attacks she suffered under Senator Warren's acerbic scrutiny. Those attacks were wholly undeserved, since the Senator's objective was to compel the SEC to focus on adopting rules that had a significant political purpose (such as the disclosure of political contributions) but only tangential relevance to the SEC's aims, as opposed to rules that should be more important to the SEC, such as those…
(a statistics site for football fans) includes a generic complaint form for readers to use when they disagree with the results of a given analysis but do not wish to engage in substantive discussion. Similarly, the Trump administration might find it useful to provide a generic form for those who wish to complain about a given individual from the private sector who is tasked with serving in the government:
[Mr./Ms.] [Name] is [completely/wholly/totally…
The new Priorities Letter offers a lot to talk about, since FINRA has managed to cover virtually every aspect of a firm's business. It is incumbent on each firm to go through the letter carefully and scrutinize every relevant priority. The following areas might be of particular interest: (i) custody, (ii) seniors, (iii) improving the automation of "suitability" reviews (e.g., the ability to search for concentrated positions, or positions with excessive turnover), and (iv) cybersecurity…