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

Readers of Dr. Litan's article and related testimony should be able to answer the Senator's questions concerning affiliations and funding. Attached please find links to both. The cover page of Dr. Litan's study contains the following language: "Robert Litan is a non‐resident senior fellow at the Brookings Institution and senior consultant to Economists Inc. Hal Singer is a senior fellow at the Progressive Policy Institute and a principal at Economists Inc. Funding for this paper was provided…

Because the MFA's comments about the benefits of market study tests are intentionally unspecific, they might go unnoticed, and that would be a shame. The SEC should be conducting ongoing tests of market structure rules to see what works and what does not instead of relying on accepted wisdom. Obviously, such testing is expensive and imposes costs on the industry. Accordingly, it is important that any such test be well designed and, ideally, part of an overall testing strategy. In the best…

 Because the MFA's comments about the benefits of market study tests are intentionally unspecific, they might go unnoticed, and that would be a shame. The SEC should be conducting ongoing tests of market structure rules to see what works and what does not instead of relying on accepted wisdom. Obviously, such testing is expensive and imposes costs on the industry. Accordingly, it is important that any such test be well designed and, ideally, part of an overall testing strategy. In the…

Ultimately, Mr. Tarullo argues for a degree of governmental control over both public and private capital that is unprecedented both in its scope, but also in its subjectivity; i.e., government regulators creating rules that might be applicable to a single institution. Even if one were to believe that the government is capable of exercising that much wisdom, one should be uncomfortable with conceding to the government as much power as Mr. Tarullo would have it take. In fact, it is not…