This White Paper is written by Commodity Futures Trading Commission (CFTC or Commission) Commissioner J. Christopher Giancarlo, a public supporter of the swaps market reforms passed by Congress in Title VII of the Dodd-Frank Act, namely clearing swaps through central counterparties, reporting swaps to trade repositories and executing swaps transactions on regulated trading platforms. The author supports the CFTC's implementation of the first two reforms, but is critical of the CFTC's implementation of the third, as explained in this White Paper. This paper (a) analyzes flaws in the CFTC's...