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
From a systems and compliance standpoint, this could be a fairly complicated rule change; e.g.:
it will require firms to compare prices and report price differentials on two trades that are in the same security and that may not have been done in contemplation of each other (this may make it more difficult to generate confirmations the next day as the price differentials must be calculated before the confirmations can be generated); it will require firms to determine…One of the main complaints of small business reps interviewed in the report was that the CFPB had no understanding of the activity it regulated. Whereas conflicts of interest can be monitored and controlled to the extent that they exist, there is no easy way to remedy a regulator's fundamental ignorance of the business they're charged with regulating. If an individual without any securities/banking experience shouldn't be put in charge of a large securities/banking firm, then how is it…
Retail firms should pay particular attention to the likely effect of the rule that relates to sales targets.
Inasmuch as Senator Warren and the AFL-CIO are united in their support for a number of disclosure measures that are considered to be either helpful to union members (such as executive pay ratio disclosures) or politically advantageous (such as political contribution disclosures), it is not surprising that the AFL should come to the Senator's aid in a given dispute with the SEC Chair. The question is this: should the SEC mandate disclosures based on (i) investors' concerns, (ii) political…