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

Given the significance of blockchain networks and utility tokens in absolute size, and their potential significance to the 21st century global economy, it is time for the SEC to move past "like should be treated alike" and on to "one size does not fit all." Congress should consider providing any necessary direction. Such legislation might be very simple; something along the lines of the following:

Study - The SEC shall conduct a study to evaluate:

(1…

This rule would be expensive to implement and would likely drive many participants from the market. Aspects of it are impractical and inconsistent with the mechanics of the securities lending business, most notably the 15-minute reporting requirement. Yet the SEC would give only a 30-day comment period that includes the holidays, and runs contemporaneously with other major rulemakings.

This is not a case where there is a current emergency or financial crisis that may provide a…

While most of these changes are formalizations of existing law or practice, firms should take the opportunity presented by this proposal to review all of their practices with respect to the sending of customer statements.

This exemption is relevant to other retail-oriented, bank-affiliated broker-dealers, the primary credit activity of which is lending under margin agreements.