Partner
Norton Rose Fulbright US LLP
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 required procedures to comply with Regulation SHO close-outs are remarkably complicated and difficult to get right. That said, Regulation SHO has been constantly on the SEC's focus list. It behooves firms to periodically recheck their procedures and to have their implementation audited by more than one person or by an outside party.
It should be expected that the SEC will look closely at any situation where a public fund underperformed a private fund or managed account with a generally similar strategy. Any adviser who is managing clients that fit that description should carefully consider the reasons for the difference in performance.
It should be expected that the SEC will look closely at any situation where a public fund underperformed a private fund or managed account with a generally similar strategy. Any adviser who is managing clients that fit that description should carefully consider the reasons for the difference in performance.
Once it is established that a particular token in a security, the SEC and other regulators have quite a number of potential charges that they may bring against market intermediaries selling or trading or facilitating such activities in the token.