Financial Services special counsel Gary DeWaal was quoted on the Commodity Futures Trading Commission's likely increase in insider-trading prosecutions related to derivatives through Rule 180.1. Gary stated, "Firms are already taking Rule 180.1 very seriously, but there has not been a lot of conscious thought put into designing a compliance program specifically around it." He noted that the usual forms for detecting insider trading will not work in these instances. Gary added, "That won't work in derivatives, where the information that is misappropriated—stolen from an employer, for instance—is never intended to be public. Over time, people will start thinking of ways to catch it, but it will not be as easy as stock insider trading. The monitoring [in the derivatives markets] is currently at the early stages at best at the broker and company level." ("CFTC Clamps Down on Insider Trading in Derivatives," May 23, 2016)