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

It does not seem like a friendly crowd.

It is unfortunately unremarkable that while the creators of Dodd-Frank were tasked with considering the potential consequences of their gargantua, they overlooked some potential flaws. Kudos, on the other hand, to Mr. Pirrong and his independent and objective analyses. Here are some additional in which Mr. Pirrong's Cassandra-like views on central clearing were reviewed.

Firms should consider how they would develop Regulation Best Interest compliance procedures that take account of the different features of traditional and non-traditional ETFs.

It would be a useful exercise to go back to the early stages of debate over Dodd-Frank and the initiation of regulation so as to collect the predictions as to what the law would accomplish. A fair number of the claims flew in the face of Econ 101, including that an increase in regulatory requirements (fixed costs) would lead to an increased number of service providers. Likewise, there were predictions that an increase in the costs of regulation would only impact "Wall Street" and leave "Main…