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
Imposing reporting requirements just adds more cost on non-dealers. Regulators should not underestimate the operational difficulty for end users of having to develop procedures and systems in order to comply with new operational requirements. Any individual new requirement may seem trivial to the regulator who imposes it, but the number of regulators is very numerous, and the number of regulations even more so. The cost burdens of so many regulators, rules and requirements…
From a systems and compliance standpoint, this could be a fairly complicated rule change; e.g.:
it will require firms to compare prices and report price differentials on two trades that are in the same security and that may not have been done in contemplation of each other (this may make it more difficult to generate confirmations the next day as the price differentials must be calculated before the confirmations can be generated); it will require firms to determine…One of the main complaints of small business reps interviewed in the report was that the CFPB had no understanding of the activity it regulated. Whereas conflicts of interest can be monitored and controlled to the extent that they exist, there is no easy way to remedy a regulator's fundamental ignorance of the business they're charged with regulating. If an individual without any securities/banking experience shouldn't be put in charge of a large securities/banking firm, then how is it…
Retail firms should pay particular attention to the likely effect of the rule that relates to sales targets.