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
Form PF, as currently drafted or as revised, produces no information of material value, when one considers how badly the Form is drafted. The financing related questions on the Form are particularly atrocious, which means the Form is ill-suited to provide useful information as to credit funds that use leverage.
But what about the music that may be lost: .
It would be better if the relevant law was simply repealed. The notion that a group of regulators may decide to regulate a previously unregulated institution as if it were a bank or bank holding company is wholly nonsensical. Banking regulation is designed for banks. Slapping bank regulation on an entity that is not a bank makes about as much sense as slapping airline regulation on a trucking company.
This is to say nothing of the fact that the power given the various…
The D.C. Circuit opinion stretches to reach a result that seems wholly inconsistent with common sense. The dissenting opinion is compelling. (See also, .)