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

Any firm carrying margin credit should review all of the new interpretations carefully. For the most part firms will benefit from the update of the interpretations and by having all of the interpretations in one place, but depending on how firms have interpreted the rules, there may also be some negative surprises.  

Firms should consider whether this may be a good time to generally review their margin compliance procedures. If a firm has not done a review for a while, it should…

A penalty of $125 million is substantial, but is a small fraction of what the SEC asked for. Further, the two principals were not required to forfeit the $600 million that they personally received. One would think Ripple and its executives are happy with the outcome. That said, this result and the SEC's decision to allow Ether ETFs to be listed on exchanges (effectively conceding that Ether is not a security, but failing to explain why it is not) raises further uncertainty as to the state of…

One may reasonably believe that permitting betting on elections is unseemly and should be prohibited on that basis. But the economic and legal arguments made against futures contracts on elections are weak, particularly as to the Presidential elections.

As to the authority of the states to regulate federal elections, surely, the federal government has authority to pre-empt any control that the states might claim over federal elections. The argument that the federal government should…

Real question: how fast does your cash go out the door on bad news?