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
This requirement is in line with the SEC's historical policy of requiring disclosure and then allowing investors to make their own investment and trading decisions based on that disclosure. Questions remain as to whether the disclosures are sufficient for customers to make informed decisions and whether the requirement of making the added disclosures may motivate broker-dealers to improve their execution practices.
It is really difficult to see any justification for not extending the comment period by another month. The rule proposals have been sitting at the SEC for years. Not only are the proposals extremely complicated in their implementation, but much has changed since they were first proposed.
Cadwalader is assisting in the representation of SIFMA in regard to the rule proposals.
It is really difficult to see any justification for not extending the comment period by another month. The rule proposals have been sitting at the SEC for years. Not only are the proposals extremely complicated in their implementation, but much has changed since they were first proposed.
Cadwalader is assisting in the representation of SIFMA in regard to the rule proposals.
The rule changes, and comments thereon, are likely to receive close review from the SEC, particularly given Commissioner Jackson's .