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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

Academics Deconstruct the Flash Crash of 2010

Kudos to the professors for providing a fulsome analysis of the CFTC's assertions. Anyone who possesses common sense and some degree of knowledge of the way in which markets work (including their unpredictability) should have recognized the absurdity of the CFTC and the Department of Justice's assertion that Mr. Sarao caused the flash crash. See, e.g., ." Streetwise Professor Pirrong also deserves recognition for pointing out how far-fetched the CFTC's…

OFR Summarizes Potential Threats to U.S. Financial Stability

The OFR's findings on central clearing seem noncommittal. According to the OFR, a central counterparty reduces risk as long as it does not default. Bear in mind, however, that a central counterparty "is a single point of vulnerability for failure."

Streetwise Professor Critiques BOE Staff Working Paper
Professor Pirrong's comments on the working paper also pertain to a number of recent studies of the effect of new regulation on liquidity in the debt market: governmental researchers are able to find that new regulations have no negative effects as long as the researchers select the right measures. In the fixed income markets, for example, researchers have found no increase in bid-offer spreads. Further, researchers found significant diminutions in trade size, resulting in positions that take…
FINRA Podcast Focuses on New Rules for Debt Research
FINRA Rule 2242, which comes into effect on February 22, 2016, imposes a comprehensive regulatory regime on debt research for the very first time. Firms that produce debt research will be required to adopt compliance policies and procedures to address both the prescriptive elements of the rule and more principles-based elements, which are intended to foster objectivity in debt research. In assessing the scope of their compliance requirements, firms should consider the following high-priority…