Guy Dempsey, a partner in the Financial Services group, commented on new Commodity Futures Trading Commission (CFTC) swap reform suggestions in this Law360 article. CFTC member J. Christopher Giancarlo issued an 89-page whitepaper detailing reform suggestions for swap trading rules. The critique offers common-sense ways to improve the market for US participants, but the ambition of the proposal could limit its actual scope. Guy commented that the whitepaper identified a number of structural issues that affect the US swap trading market. "The fragmentation is now structural," he said. "There's now a lot of random forces that arbitrarily create barriers to liquidity." Guy also noted some marginal fixes to swap trading rules that may end up happening, such as elimination of the requirement that a swap execution facility (SEF) has to have a copy of the International Swaps and Derivatives Association master agreement between swap counterparties trading on the SEF. ("CFTC Swaps Reform Seen as Big Plan With Steep Climb," January 30, 2015)