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

The evidence for the benefits of position limits in the energy market is not well established. See, e.g., . Notably, when energy prices crashed, no speculators went bankrupt - which would seem very strongly to suggest that there were no speculators previously hoarding oil. Further, if energy prices go very high, energy producers are able to pump/produce more. The ability of speculators to effect prices of energy seems dwarfed by the power of sovereign nations to respond to price movements.…

The FSOC move towards imposing restraints on a particular type of activity, rather than on an individual entity, is extremely significant in preventing potential abuses of power. It will limit the ability of FSOC to single out a company that may be in the disfavor of the ruling political party. While this move is to the good, it would be better still if Congress would actually adopt legislation that would confine FSOC's discretionary power rather than rely upon FSOC to police itself.

According to prior news reports, the LTSE will establish listing requirements that are significantly different from those on other exchanges. In particular, it was reported that the exchange's listing requirements would permit the listing of issuers whose corporate organizational documents gave greater voting rights to corporate founders and other investors that had held their shares for a longer period, rather than to later investors. The CII had objected that there would be no time limit…