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

One common theme that runs through the report: "Respondents have indicated that there are impediments to the development of sustainable finance, such as the lack of reliable and credible data and the lack of standards to promote comparability between sustainable investments" (at page 23). If there is some more limited, specific, and definable objective that IOSCO believes can improve disclosure standards, then IOSCO should specify and define it. Otherwise, "sustainable finance" remains too…

If the CFTC is going to extend comment periods, why not a month, or two months? Why two days? Of all the extensions granted during the pandemic, this must be the shortest.

Excerpt from Swann's Way, Remembrance of Things Past, Volume One, Marcel Proust (1871–1922): "The hour when an invalid, who has been obliged to start on a journey and to sleep in a strange hotel, awakens in a moment of illness and sees with glad relief a streak of daylight shewing under his bedroom door. Oh, joy of joys! it is morning. The servants will be about in a minute: he can ring, and some one will come to look after him. The thought of being made comfortable gives him strength to…

From an economic perspective, this rule proposal is quite similar to the FRB's so as to exclude from the calculation riskless assets. While both of these measures are a response to what is becoming an economic crisis, they also reflect that leverage ratios and capital requirements that do not take account of the actual risk of assets make very little sense. While the banking regulators instituted such measures in the wake of Dodd-Frank, the coronavirus is causing them to be revisited. The…