Pro-Reform Reconsideration of the CFTC Swaps Trading Rules: Return to Dodd-Frank

Yesterday, January 28, 2015, Commodity Futures Trading Commission (CFTC) Commissioner J. Christopher Giancarlo released a White Paper titled “Pro-Reform Reconsideration of the CFTC Swaps Trading Rules: Return to Dodd-Frank.” According to the CFTC's website, "the paper analyzes flaws in the CFTC’s implementation of its swaps trading regulatory framework under Title VII of the Dodd-Frank Act and proposes a more effective alternative."  The White Paper is available here.  The paper has a 3 page executive summary and is over 80 pages in total.  The paper includes 303 footnotes.  While not a critical concern, it is noted that the paper is light on illustration, and accordingly, I would propose that the image below be added to the paper, in the event that the paper is updated in the future.