Analysis of Market Manipulation

Brattle is an industry leader in the detection, analysis, and proof (or disproof) of manipulative behavior in energy, commodity, financial, and securities markets.

We are well-versed in the analysis of manipulation as alleged under the fraud-based anti-manipulation rules of the Federal Energy Regulatory Commission (FERC), Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission (SEC), and Federal Trade Commission (FTC), as well as equivalent rules in place in the European Union. We have also worked on manipulation cases brought pursuant to state laws or actions by the U.S. Department of Justice (DOJ). We provide clients with a holistic perspective concerning the types of behavior that these agencies may deem manipulative.

Our approach is based on a logical framework that evaluates behavior in a manner that is analytically consistent with past enforcement outcomes and current enforcement cases. Because our approach is objective, its application can be equally useful for the disproof or proof of manipulation. We have used it successfully to provide analytical support and expert testimony to address government investigations of alleged manipulative behavior and to defend against charges of manipulation raised in government enforcement actions and related civil litigation.

Areas of Expertise

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Dr. Goldberg specializes in complex litigation in which careful analysis and modeling of economic, business, or financial data is critical. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
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Mr. Laursen is an expert in financial products and institutions, markets, regulation, and risk management. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
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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. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
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Dr. Oldfield is an expert in financial economics, including mortgage securitization, trading strategies, market making, corporate bond valuation, financial derivatives, and risk management. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
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Mr. Taylor's areas of expertise include contract and market risks and incentives, antitrust and regulatory economics, and transition markets. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
Senior Associates
Senior Associate
Dr. Rachael Barza has worked on cases concerning valuation and damages, state aid, abuse of dominance, cartels, and acquisitions, before the European Competition Commission and various European high courts. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
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Senior Associate
Dr. Nunez has corporate and consulting experience in finance, valuation, and trading. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
Verlinda web
Senior Associate
Dr. Verlinda specializes in industrial organization, antitrust, econometrics, and statistics. More icon f02782c24cccaf6d90e1da53920c42f20e5a8955f54ac2ca5727ec7dc89987b4
Market Manipulation in Energy-Related Markets
August 2017
Published in the American Bar Association's (ABA) Transportation and Energy Industries Digest
Building an Effective Trade Surveillance System: A Framework-Based Approach using Guidance from Two Recent FERC White Papers
March 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.

January 26, 2017
Presented at the Electric Utility Consultants, Inc. (EUCI) conference, “Financial Transmission Rights (FTRs/CRRs/TCRs)”
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, and Peter S. Fox-Penner
Published by PUR Inc.
Market Manipulation Push is Widening the Compliance Gap
January 23, 2015
Published in
A Framework for Market Manipulation Compliance and Enforcement
January 2014
Presented to the Houston Chapter of the Energy Bar Association, Houston, TX
Uneconomic trading and market manipulation
July 2013
Published in Energy Risk
A Unifying Approach to Market Manipulation Compliance
June 2013
Presented at the Platts European Gas and Power Trading Conference, London, UK
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
A Framework for Analyzing Market Manipulation
September 2012
Published in Review of Law & Economics, Volume 8, No. 1
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
Completing the Puzzle: Defining Manipulation Under REMIT
January 2012
Published by The Brattle Group, Inc.
Losing Money to Increase Profits: A Proposed Framework for Defining Market Manipulation
March 2011
Published by The Brattle Group, Inc.