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

See also , which is intended to put additional regulatory constraints on firms that employ a significant number of individuals with checkered pasts.

IOSCO's Report identified many of the same concerns raised by SEC Commissioner Hester Peirce, who has been urging the SEC not to .

There is one investor qualification definition that even an SEC that favors investor protection over investor choice should reconsider: "Qualified Purchaser."

Generally, "accredited investors" (which is a fairly low standard of wealth and income) are permitted to invest in private funds exempt from registration under the Investment Company Act by virtue of Section 3(c)(1), which limits these funds to less than 100 investors. To invest in a Section 3(c)(7) private fund, which has no…