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 complicated as the rules are at the federal level, the problem is now compounded by the states going their own way on a wide variety of issues from AML to suitability to privacy to the treatment of senior accounts. While one may argue for or against any individual piece of state regulation, in the aggregate the increased Brexitization of regulation is going to be a significant drain on the economy.

If you are going to have affairs, you need to have a better acronym. For example: Affairs and Communications, External. Then the acronym would be "ACE," which is cool.

This is not a good direction for financial regulation. Each state regulator going its own way is like a version of Brexit. The economic consequences of state-by-state regulation for the national market would be significant.

Should the regulators be approving credit models based on whether they are happy with the results? What happens if another credit scoring metric produces different or less favored results: does that metric become illegal to use without regard to the process of its production or its accuracy?

Big data raises lot of important social/moral questions; and "disparate impact" is one of the more complex ones. For some background discussion of "big tech," "big data" and credit scoring, see…