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Wuslich, Raymond

Coffee, Gordon

Energy, Project Development & Finance

Energy Regulatory-FERC

Energy Industry Transactions

Energy Industry Investigations and Litigation

Energy and Utilities

May 21, 2012

Cracking Down On Cross-Market Hedging

Gordon A. Coffee , Raymond B. Wuslich

The Federal Energy Regulatory Commission insists that its rules concerning manipulative energy transactions are clear, and that it has the jurisdiction to pursue manipulation claims wherever the trail may lead, even if it is to markets that lie beyond its traditional stomping grounds in wholesale gas and electric markets for physically delivered products. But industry observers question both propositions.

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