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
Mr. Dudek has had a long and distinguished career as a public servant.
FSOC deserves credit for rescinding its original SIFI designation. It should specify fully the criteria used for the determination and the removal of its designation, as well as the procedures involved in making it. Notwithstanding this action taken by the FSOC, Congress should revisit the provisions of Dodd-Frank that established the designation process, and should reconsider whether it was good government to grant such open-ended authority to a regulatory…
How much of the SEC's focus on "disclosure" is driven by the interests of investors? Is it really true that corporations would better serve their investors if their disclosures spotlighted the risks of climate change, or does that proposed requirement reflect a political preference? If it is the latter, wouldn't most investors be more concerned about the risks that might arise from Brexit, Zika and other pandemics, governmental defaults on both national and municipal levels, aging…
Dodd-Frank's established standards for designating financial institutions as "systemically significant" are impossibly open-ended. They include ten factors that may be interpreted in nearly every way conceivable. These can be ignored entirely or considered along with other factors that are not specified in the legislation. Read literally, the standards give FSOC complete authority to improvise interpretations as it goes along. That is bad public policy. To grant such unfettered…