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

Chair Giancarlo's remarks are a blunt criticism of prior rulemakings. Mr. Giancarlo has been consistent in arguing that, while the government should regulate markets, it should not dictate or reinvent market structures (and, if it is so ambitious as to do so, it should at least check whether its dictates are having the intended effect). Notwithstanding this criticism of prior rulemakings, the Chair has nothing but good things to say about Dodd-Frank. Even those who do not share this optimism…

While regulators might obtain some benefit through the centralization of information provided by CAT, it is unclear how that benefit can be sufficient to outweigh the risks of centralizing so much financial information about so many individuals. If regulators worry about "too big to fail," isn't it just as sensible to worry about "too much data to store in one place"?

From a financial policy standpoint, the SEC's renewed focus on its traditional economic missions (good disclosure, investor protection) is an important change in priorities. When combined with a rulemaking agenda that is limited to achievable and announced goals, businesses are better able to prepare.

Not so long ago, CFTC Commissioners were imagining the adoption of U.S. regulations that would have required the rest of the world to acquiesce. . The current Chair is now left to see if peace can be made.