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

According to FDIC Chair Gruenberg, "[t]he fact that the credit rating agencies have lowered the credit ratings of the eight U.S. globally systemic banking organizations (G-SIBs) because of a reduced expectation of taxpayer support in the event of failure is a sign of progress." Suppose, instead, that the rating agencies had raised the credit rating of large U.S. banks. What conclusion should be drawn? The reality is that it is impossible to demonstrate with mathematical certainty either the…

Commissioner Behnam's first published speech covers a lot of ground, but does not suggest that there are new initiatives that he will spearhead or that there are current initiatives that he opposes. Instead, Mr. Behnam indicates he will be in observation mode for the first part of his tenure.

In many ways, Mr. Behnam's speech is similar to the by CFTC Chair J. Christopher Giancarlo on Monday. Both Mr. Giancarlo and Mr. Behnam expressed broad support for the policy aims of Title VII…

The extension is consistent with . Presumably, by the time this no-action letter expires, the relevant rules will be fixed.

This is a very clear message to firms that they must review their order routing and best-execution procedures.