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Policing Market Manipulation: A Review of Evolving Federal Energy Regulatory Commission Policy



To date the Federal Energy Regulatory Commission has not meaningfully articulated for market participants a clear definition of what market manipulation is and how it may be avoided. Nor has FERC acted through rulemakings, policy statements, or no-action letters to provide additional clarity. As a result, the law of market manipulation at FERC still remains largely unwritten.

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