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Dr. Ledgerwood is an expert in market competitiveness with an emphasis on the economic analysis of potential market manipulation claims in commodities and securities markets.

He specializes in the analysis of competitive matters within and across physical and financial markets; issues pertinent to economic regulation, ratemaking, and resource planning; asset valuations; and analyses pursuant to matters in tort, contracts, or involving fraud. His twenty-three years of experience as an economist and an attorney allow him to provide clients with unique insights into matters involving potential litigation, especially as they relate to meeting burdens of proof under statutory requirements.

As a former economist and attorney for the Office of Enforcement for the Federal Energy Regulatory Commission (FERC), he evaluated manipulative behavior within and across wholesale electricity and natural gas markets. This experience led him to develop a framework for detecting and analyzing manipulative behavior. The framework separates actions that cause the manipulation from those that benefit from its effect, simplifying the proof (or disproof) of the manipulation. This logic is particularly useful in assisting clients in maintaining compliance and for supporting or defending enforcement actions brought under the anti-manipulation rules in place in the U.S. and EU.

Dr. Ledgerwood has testified as an expert witness before state utility commissions and in federal court. He previously taught graduate courses in microeconomic theory, regulation, law and economics, antitrust and remedies at the University of Oklahoma and was an Affiliated Faculty member at the Georgetown University Public Policy Institute.

Representative Engagements
Defense against FERC investigation for suspected market manipulation
Assisting a large electricity trader in evaluating its potential exposure given an agency investigation into the industry’s financial trading activity. Analysis uses the trader’s internal trading records and publically available data from the Regional Transmission Organization (RTO) to evaluate if there is potential liability under the FERC’s anti-manipulation rule, as evaluated using the framework. Where concerning behavior is found, we review other client records to determine whether the trading at issue served a stand-alone legitimate business purpose, thus exonerating potential assertions of manipulative intent.
Analysis of a suspected market manipulation
Examined the behavior of commodity traders across specific trading days in which manipulative behavior was suspected to occur. Involved the analysis of various physical and financial positions in relation to emails and deposition transcripts provided by the agency sponsoring the work.
Evaluation of applicability of research tax credit
Evaluated whether contracts involving highly specialized and unique research were “funded” within the context of the applicable statute. Examined various contractual provisions to determine whether the risk of non-performance due to the research is borne by the buyer or seller of these contracts.
Damages for antitrust violations in discount grocery market
Assisted a local grocer facing below-cost pricing by a large, multi-product national chain. Participated in all phases of the analysis to establish the sustainability of the predatory scheme and to assess damages associated therewith.
Internal evaluation of suspected manipulative activity
Assisted a client with analyses and presentation materials relevant to specific physical energy and derivatives trading activity that occurred contemporaneously with a chain of instant messages. Transactional analysis involved a dynamic trading book consisting of multiple interrelated financial and physical instruments.
Compliance seminars for major utilities and trading houses in the U.S. and EU
These seminars provide traders with a way to think about manipulative behavior proactively, emphasizing their obligation for compliance given agency willingness to prosecute individuals for manipulation.
Publications
Article
Derivatives' Roles in Manipulation
October 2017
Published in the Futures and Derivatives Law Report, Volume 37, Issue 9

The article, published in the October 2017 issue of The Journal of the Law of Investment & Risk Management Products Futures & Derivatives Law Report, discusses the role derivatives play in market manipulation.

Article
Market Manipulation in Energy-Related Markets
August 2017
Published in the American Bar Association's (ABA) Transportation and Energy Industries Digest
Report
Building an Effective Trade Surveillance System: A Framework-Based Approach using Guidance from Two Recent FERC White Papers
March 20, 2017
Published by The Brattle Group, Inc.

The whitepaper outlines a cost-effective, learning-driven approach for companies to develop in-house trade surveillance systems to analyze potentially manipulative behavior.

Presentation
Summary of the FERC White Papers on Compliance and Enforcement
January 26, 2017
Presented at the Electric Utility Consultants, Inc. (EUCI) conference, “Financial Transmission Rights (FTRs/CRRs/TCRs)”
Article
D.C. Circuit Clarifies that SEC Need Not Show Market Impact in Manipulation Cases
December 09, 2015
Published in the ABA's Securities Litigation Journal
Article
Coscia Verdict Highlights Different Approaches to High-Frequency Trading
November 12, 2015
Published in Practice Points, a publication of the ABA’s Securities Litigation Committee
Book
Market Power and Market Manipulation in Energy Markets: From the California Crisis to the Present
April 2015
Gerald A. Taylor, Shaun D. Ledgerwood, Romkaew P. Broehm, Peter S. Fox-Penner, Shaun D. Ledgerwood, Gerald A. Taylor, Peter S. Fox-Penner, and Romkaew P. Broehm
Published by PUR Inc.
Presentation
Differentiating a Legitimate Hedge From a Target for Manipulation
February 19, 2015
Presented at the EUCI Conference on Integrating Energy Trading, Valuation, Market and Credit Risk Management, Denver, CO
Article
Market Manipulation Push is Widening the Compliance Gap
January 23, 2015
Published in Risk.net
Presentation
The Chasm between Following Market Rules and Fraud
December 04, 2014
Presented to the Stanford Program on Energy and Sustainable Development
Article
An Economic Evaluation of 'Funding' for Research Tax Credits
September 29, 2014
Published in Tax Notes
Presentation
Uneconomic Trading as Transactional Fraud: EU Compliance Lessons From the US
April 23, 2014
Presented to AIGET
Presentation
Market Manipulation and Antitrust: Complements or Substitutes?
February 25, 2014
Presented to the NYC Bar Association Antitrust & Trade Regulation Committee
Presentation
A Framework for Market Manipulation Compliance and Enforcement
January 2014
Presented to the Houston Chapter of the Energy Bar Association, Houston, TX
Article
Using Virtual Bids to Manipulate the Value of Financial Transmission Rights
November 2013
Published in The Electricity Journal, Vol. 26, Issue 9
Presentation
A Holistic Approach to Market Manipulation Compliance
August 2013
Presented to the energy trading and compliance staff of a multinational financial institution, New York, NY
Article
Uneconomic trading and market manipulation
July 2013
Published in Energy Risk
Presentation
Market Manipulation post Hunter vs. FERC: A Framework for Unified Analysis
June 2013
Panel presentation delivered at the Harvard Electricity Policy Group’s 71st Plenary Session, Calgary, AB
Presentation
A Unifying Approach to Market Manipulation Compliance
June 2013
Presented at the Platts European Gas and Power Trading Conference, London, UK
Presentation
A Perspective on Market Manipulation
May 2013
Presented at an anti-manipulation compliance seminar for the traders and compliance staff of a major U.S. electricity trading company
Presentation
A Holistic Approach to Market Manipulation Compliance
May 2013
Presented to the partners of an international law firm interested in applications to energy, commodities and securities trading, Brussels, Belgium
Presentation
A Case Study of an Alleged Market Manipulation: Deutsche Bank
April 03, 2013
Presented to the Energy Bar Association
Presentation
ISO/RTO Financial Products and Recent Trends in FERC Enforcement
April 2013
Panel presentation sponsored by the Energy Bar Association Electricity Regulation Committee and the Compliance and Enforcement Committee, Washington, DC
Presentation
Uneconomic Trading in Energy Markets: A Framework of Market Manipulation
April 2013
Presented at the Penn State Faculty Colloquy, State College, PA
Presentation
A Holistic Approach to Market Manipulation Compliance
April 2013
Presented to the partners of a national law firm interested in applications to energy, commodities and securities trading, Washington, DC
Presentation
A Holistic Approach to Compliance: REMIT and the MAD
April 2013
Presented at an anti-manipulation compliance seminar for the traders and compliance staff of a major European energy trading company
Presentation
Market Manipulation in Wholesale Electricity Markets
March 2013
Presented to the NP Market Council
Presentation
An Economic Approach to FERC Anti-Manipulation Compliance
March 2013
Presented at an anti-manipulation compliance seminar presented in separate sessions to the compliance staff and traders of a major commercial energy trading company
Presentation
Market Manipulation Cases in U.S. Wholesale Electricity and Natural Gas Markets
February 2013
Presented at the Bird & Bird Seminar on Market Abuse, London, UK
Presentation
Market Manipulation in Wholesale Electricity and Natural Gas Markets
January 2013
Presented for the West LegalEd CLE program (webinar)
Presentation
Recent Market Violations and Their Repercussions on Compliance and Counterparty Risk
November 2012
Panel Moderator and presenter at the EUCI Conference on Credit & Counterparty Risk, Baltimore, MD
Presentation
Meeting Cross-Border Requirements: Understanding Changing International Regulations and Ensuring Global Compliance
November 2012
Panelist and presenter at the ACI Energy Trading Compliance and Regulatory Enforcement Conference, Washington, DC
Presentation
An Economic Approach to FERC Anti-Manipulation Compliance
November 2012
Presented at an anti-manipulation compliance seminar, separate sessions to the gas and electricity trading groups of a major utility’s trading group
Presentation
Using Virtual Bids to Manipulate the Value of Financial Transmission Rights
November 2012
Presented at the USAEE/IAEE Annual Conference, Austin, TX
Article
A Framework for Analyzing Market Manipulation
September 2012
Published in Review of Law & Economics, Volume 8, No. 1
Presentation
FERC’s Anti-Market Manipulation Rule and the Impact on Physical and Virtual Market Participants
August 2012
Panel moderator and presenter at the EUCI FTR Conference, Houston, TX,
Article
Rummaging through the Bottom of Pandora’s Box: Funding Predatory Pricing through Contemporaneous Recoupment
April 2012
Shaun D. Ledgerwood and Wesley Health
Published in Virginia Law and Business Review, Volume 6, Number 3
Presentation
An Analytical Framework for Anti-Manipulation Compliance, Monitoring, and Enforcement
April 2012
Presented at the Marcus Evans Conference on European Energy Market Integrity: REMIT & Regulatory Compliance, London, UK
Article
A Comparison of Anti-Manipulation Rules in U.S. and EU Electricity and Natural Gas Markets: A Proposal for a Common Standard (Russian Translation)
April 2012
Published in Energy Law Journal
Article
A Comparison of Anti-Manipulation Rules in U.S. and EU Electricity and Natural Gas Markets: A Proposal for a Common Standard
April 2012
Published in Energy Law Journal
Report
Completing the Puzzle: Defining Manipulation Under REMIT
January 2012
Published by The Brattle Group, Inc.
Article
Market Manipulation in Wholesale Electricity Markets
2012
Published by Energy Law Journal, Volume 33, Number 1, Cyrillic translation
Presentation
Energy Trading Compliance and Enforcement Post Dodd-Frank: A Framework of Market Manipulation
2012
Presented at an anti-manipulation compliance seminar for law firms, Washington, DC (January and March 2012)
Presentation
The Search for a Uniform Definition of Market Manipulation: A Proposed Framework
October 2011
Presented at a Conclave Concerning the REMIT, London, UK
Presentation
Triggers and Targets: A Framework for Analyzing Market Manipulation
July 2011
Presented to the American Gas Association, Washington, DC
Presentation
Manipulation of FTR Markets
July 2011
Presented to EUCI’s Conference on Financial Transmission Rights, Houston, TX
Article
Market Manipulation Without Market Power
June 2011
Published in Law360
Report
Protecting Market Integrity by Defining Market Manipulation
June 2011
Published by The Brattle Group, Inc.
Presentation
A Framework for Defining Energy Market Manipulation
May 2011
Presented to the Bracewell & Giuliani LLP Energy Compliance Network , Houston, TX
Presentation
Market Manipulation
February 2011
Panel presentation at Skadden’s 6th Annual Enforcement and Compliance Conference with John Estes III and Joseph Kalt, Washington, DC
Report
Screens for the Detection of Manipulative Intent
December 2010
Available from Social Science Research Network (SSRN)
Presentation
The Impact of FERC’s Anti-Manipulation Statute on FTRs and Related Positions
July 2010
Presented at EUCI’s Conference on Financial Transmission Rights, Alexandria, VA
Article
Section 6: Natural Gas Capacity Release and Electricity Transmission Reassignment
August 2009
In 2008 State of the Markets Report, Published by the Division of Energy Market Oversight, Office of Enforcement, Federal Energy Regulatory Commission
News & Events
February 21, 2018
Shaun Ledgerwood and John Tsoukalis to Present at Energy Risk Event on Trade Surveillance & Market Compliance for Energy Trading Organizations

Brattle Principal Shaun Ledgerwood and Senior Associate John Tsoukalis will present at Energy Risk’s training event, “Trade Surveillance & Market Compliance for Energy Trading Organizations,” taking place February 21-22, 2018 in Houston, TX.

January 29, 2018
Shaun Ledgerwood and John Tsoukalis to Present at EUCI Conference on Financial Transmission and Auction Revenue Rights

Brattle Principal Shaun Ledgerwood and Senior Associate John Tsoukalis will present at Electric Utility Consultants, Inc.’s (EUCI) conference, “Financial Transmission and Auction Revenue Rights (FTRs/CRRs/TCRs/ARRs),” taking place January 29-30, 2018 in Washington, DC.

January 17, 2018
Brattle Economists Author Article on Derivatives' Roles in Manipulation

Brattle Principal Shaun Ledgerwood and Senior Associate Jeremy Verlinda have authored an article published in the October 2017 issue of The Journal of the Law of Investment & Risk Management Products Futures & Derivatives Law Report, which discusses the role derivatives play in market manipulation.

October 26, 2017
Shaun Ledgerwood to Present at Platts’ 10th Annual Nodal Trader Conference

Brattle Principal Shaun Ledgerwood will present at Platt’s 10th Annual Nodal Trader Conference on FTR Litigation and Risks, Updates on Compliance, and Supporting the Mexican Market, taking place October 26-27, 2017 in New York, NY.

August 01, 2017
Article by Drs. Shaun Ledgerwood and Jeremy Verlinda on Energy Manipulation Cases Published in ABA Transportation and Energy Industries Digest

Brattle economists Shaun Ledgerwood and Jeremy Verlinda review two recent energy-related manipulation cases where the plaintiffs claimed antitrust harms, but received very different outcomes following Motions to Dismiss.

July 20, 2017
Brattle to Host ABA Market Manipulation Teleconference

The Brattle Group will host the upcoming American Bar Association (ABA) teleconference, “Market Manipulation: When Is It An Antitrust Issue?,” taking place on Thursday, July 20, 2017 from 12:00 – 1:00 PM EST.

April 18, 2017
Shaun Ledgerwood to Participate in K&L Gates Seminar on Energy Trading Policy

Brattle Principals Shaun Ledgerwood will present at K&L Gates Seminar, “Looking Over the Horizon: Energy Trading Policy, Compliance, and Enforcement Trends in Today’s Evolving Regulatory Landscape,” taking place April 18, 2017 in Houston, TX.

March 20, 2017
Building an Effective Trade Surveillance System: Guidance from FERC White Papers

Brattle Principal Shaun Ledgerwood and Associate John Tsoukalis have authored a white paper that outlines a cost-effective, learning-driven approach for companies to develop in-house trade surveillance systems to analyze potentially manipulative behavior.

February 23, 2017
Shaun Ledgerwood Featured in Risk.net article on FERC Manipulation Standards

Brattle Principal Shaun Ledgerwood has been featured in a Risk.net article that discusses the need for greater clarity around the U.S. Federal Energy Regulatory Commission’s (FERC) anti-manipulation standards.

January 26, 2017
Shaun Ledgerwood to Present at EUCI Conference on Financial Transmission Rights

Brattle Principal Shaun Ledgerwood will present at the Electric Utility Consultants, Inc. (EUCI) conference, “Financial Transmission Rights (FTRs/CRRs/TCRs),” taking place January 25-26, 2017 in Washington, DC.

October 07, 2016
Shaun Ledgerwood to Moderate Market Manipulation Panel at Global Antitrust Economics Conference

Brattle Principal Shaun Ledgerwood will present at the Global Antitrust Economics Conference, taking place October 7, 2016 at Northwestern University’s Pritzker School of Law in Chicago, IL.

January 15, 2016
Shaun Ledgerwood and Gary Taylor Co-Author Article on Lasting Effects of Enron’s Power Market Schemes on the U.S. Anti-Manipulation Agenda

Brattle Principals Shaun Ledgerwood and Gary Taylor recently published an article on Risk.net discussing how failures of the first liberalized power market in the U.S. continue to shape the Federal Energy Regulatory Commission’s (FERC) anti-manipulation agenda fifteen years after the California energy crisis.

December 09, 2015
Brattle Economists Author Article on Proof of Intent in the SEC

Brattle principals Shaun Ledgerwood and Paul Hinton recently authored the article “D.C. Circuit Clarifies that SEC Need Not Show Market Impact in Manipulation Cases” for the American Bar Association’s Securities Litigation Committee.

November 12, 2015
Brattle Economists Comment on Coscia Verdict and Different Approaches to Enforcement in High-Frequency Trading Markets

Brattle principals Paul Hinton and Shaun Ledgerwood have contributed to Practice Points, a publication of the ABA’s Securities Litigation Committee, on the topic of the recent Coscia verdict and enforcement trends in high-frequency trading markets.

October 09, 2015
Paul Carpenter and Shaun Ledgerwood to Present at Energy Bar Association Western Chapter’s Second Annual Canadian Program

Brattle principals Paul Carpenter and Shaun Ledgerwood will present at the upcoming Energy Bar Association (EBA) Western Chapter’s Second Annual Canadian Program, taking place on October 9, 2015 in Calgary, Canada.

July 28, 2015
Shaun Ledgerwood to Chair Panel on Analysis of Market Manipulation at EUCI FTR Conference

Brattle principal Shaun Ledgerwood will chair a panel titled, “What Trading Organizations Can Do to Proactively Manage Swaps Manipulation Risks” at EUCI’s Conference on Financial Transmission Rights, to take place on Tuesday, July 28, 2015 at the Key Bridge Marriott in Washington, DC.

May 20, 2015
Brattle to Sponsor Symposium on Market Power and Market Manipulation in Energy Markets

The Brattle Group will be sponsoring the upcoming program, “A Symposium on Market Power and Market Manipulation in Energy Markets," taking place Wednesday, May 20th, 2015 and hosted by the Center for Business & Public Policy at Georgetown University's McDonough School of Business.

April 14, 2015
Brattle Consultants Release Book on Market Power and Market Manipulation in Energy Markets

Brattle principals Gerald Taylor, Shaun Ledgerwood, Romkaew Broehm, and Peter Fox-Penner have authored a book that provides insights and an analytical framework for understanding the legal and economic nuances associated with energy market manipulation. Market Power and Market Manipulation in Energy Markets: From the California Crisis to the Present will be published in April 2015 by PUR Inc.

March 31, 2015
Shaun Ledgerwood to Speak on Market Manipulation in U.S. Electricity Markets at Gulf Coast Power Association Spring Conference

Brattle principal Shaun Ledgerwood will speak on the current state of market manipulation activity in the U.S. electricity markets at the upcoming 29th Annual Gulf Coast Power Association (GCPA) Spring Conference.

December 10, 2014
Shaun Ledgerwood to Speak at EUCI Conference on Integrating Energy Trading, Valuation, Market and Credit Risk Management

Brattle principal Shaun Ledgerwood has been selected to present at an upcoming EUCI conference, “Integrating Energy Trading, Valuation, Market and Credit Risk Management,” taking place December 10-11, 2014 in Scottsdale, AZ.

September 29, 2014
Darrell Chodorow and Shaun Ledgerwood Publish Article for Tax Notes on Funding for Research Tax Credits

Dr. Shaun Ledgerwood and Mr. Darrell Chodorow published an article in the September 2014 issue of Tax Notes in response to a recent summary judgment order in Geosyntec Consultants Inc. v. United States, presenting an alternative approach based on the economics of risk and reward allocation for contracts.

August 14, 2014
Shaun Ledgerwood Featured in New York Times Article on the Risks of Market Manipulation in the Electric Grid

Brattle principal Shaun Ledgerwood was quoted in The New York Times article “Traders Profit as Power Grid Is Overworked,” which discusses the recent trend of energy traders and banks profiting as a result of the increasingly congested electric grid as it struggles to meet demand.

June 20, 2014
Shaun Ledgerwood Quoted in EnergyRisk Article Discussing Increased Use of Surveillance Technology in Commodities Trading

Principal Shaun Ledgerwood was recently cited in an EnergyRisk article on the use of technology in monitoring commodities trading for potential manipulation-like behavior.

Personal Interests

Shaun is a native of Norman, Oklahoma, where he attended and taught law and economics classes at the University of Oklahoma from 1983-1986 and 1989-2008 and where he still has season football tickets for his beloved Sooners.

From 1997-2008, he worked as a consulting economist for C.H. Guernsey & Company in Oklahoma City. While there, he learned the “physical side” of the electric industry from his many engineer colleagues, as well as the regulatory processes associated with ratemaking and the rise of competitive electricity markets. Shaun’s teaching and consulting interests eventually coalesced into a practice focused on regulatory economics, competition-related analyses, and the evaluation of liability and damages claims for cases in contract and tort.

In 2008, he and his wife moved to downtown Washington, DC to pursue a career with the Federal Energy Regulatory Commission’s Office of Enforcement. While there, he worked on many of the major market manipulation enforcement cases brought by the agency, coming to know several of his colleagues at Brattle as a result. Shaun joined Brattle in January 2011 to build a practice area focused on market manipulation in securities and commodities markets.

Shaun has been a member of the Oklahoma Bar Association since 1990, and is presently a member of the American Bar Association, Federal Energy Bar Association, American Economic Association, the United States Association of Energy Economics, the International Association of Energy Economics, and Phi Beta Kappa.

His wife and he continue to live and prosper in DC, happily enjoying the many restaurants, theaters, and other activities the city and surrounding areas provide.