Partner
Norton Rose Fulbright US LLP
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
As a general matter, the changes would have the effect of potentially driving trades in securities, particularly trades initiated by retail investors, to the national securities exchanges rather than being internalized by a broker-dealer (or sent by the firm receiving the retail order to a market maker that sent "payment for order flow" to the firm that had received the order).
The question is whether these changes would result in better market prices that are…
Secretary Yellen has been fighting an uphill battle, first having to defend President Biden's claim that inflation would be transitory and now arguing that additional spending will decrease inflation.
In theory, the concept of no-action letters is great. Having a difficult question, call up the agency staff, and get an answer.
However, as a practical matter, that process is only useful if (i) the agency leadership empowers the staff to make decisions and (ii) the staff is not afraid to give favorable advice. If the staff can not make provide answers, or will only provide the most burdensome / restrictive answer to every question, then there is no reason for anyone to…
The research paper asks, "How can [central banks] establish credibility for being responsive to climate change when relatively little is known about how it interacts with the real and financial economy?" According to the paper, the answer to this question is that central banks should use "sharper communication with more precise language."
There is an alternative approach to the question posed in the paper; i.e., that the banking regulators should continue to use extremely uncertain…