Davy V. H. Nguyen, in the paper 'Too Big to Fail? Towards a Sovereign Bankruptcy Regime', Cornell International Law Journal, Volume 45 (2010): 697-722 (available at www.lawschool.cornell.edu/research/ilj/upload/nguyen-final.pdf) has discussed the issue with intelligence. Nguyen shows that free-market approaches (CACs, and pari passu clauses) are not sufficient, and that a sovereign bankruptcy regime needs to be established. There is no excuse for political leaders to procrastinate, and to keep putting free trade talks (TTIP) before more urgent sovereign bankruptcy regime talks. With regard to Argentina's debt restructuring, Nguyen recounts (p.713) how: "In 2001, Argentina had 152 types of bonds, issued in seven different countries and governed by the laws of eight different countries. The result was that failure to approve the debt-restructuring plan in one agreement made disagreeing parties holdout creditors". It is the holdout creditors who have now been upheld by the US Supreme Court. This legal precedent means that the private-market approach (CACs and pari passu clauses) to sovereign debt restructuring, an approach that Jeffrey Frankel nostalgically claims "worked, more or less", is itself utterly bankrupt: yet another promise of self-regulating free-markets in shambles, and exactly as various scholars (Patrick Bolton, Olivier Jeanne, Steven L. Schwarcz, Philip Wood) predicted. When is scholarship going to be respected, and ideology (the ideology of private-market solutions) put where it belongs?