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.