Steven Lofchie is a Partner based in New York. He advises financial institutions and corporate clients on the securities laws and the Commodity Exchange Act, with particular focus on the regulation of broker-dealers, swap dealers, investment funds and other market intermediaries. Steven's transactional practice focuses on securities credit and derivative transactions.

Recent Articles & Comments

The recipients of the letters are a somewhat eccentric collection of businesses. A number of the recipients were actually providing false information about other sites with which the recipients have no obvious connection. For example, lists 10 crypto exchanges that it claims are FDIC-insured. FDICCrypto redirects to , which seems to be a combination of a limousine service, crypto business and music site. An interesting business mix.

The SIFMA AMG letter makes explicit that the Supreme Court decision in , which "raises concerns about the Commission’s ability to implement both the Proposal and the Climate Disclosure Rule under the 'major questions' doctrine," threatens this SEC rulemaking. It is likely that the SEC will be defending administrative law challenges concerning this and other proposed rule changes over the next few years. While financial market participants have been historically reluctant to challenge the SEC…

If one did not know better, one might think that the SEC staff is actively trying to discourage investments in small private issuers. . .

See . The speech and the letter are not entirely inconsistent, but the tone is quite different.