Last week, the Staff of the Commodity Futures Trading Commission (CFTC) issued Staff Advisory 14-21 on the subject of “Gramm-Leach-Bliley Act Security Safeguards.” The CFTC had issued guidance previously in Part 160 of the CFTC’s regulations on “Privacy of Consumer Financial Information” (April 27, 2001). Swap Dealers (SDs) and Major Swap Participants (MSPs)