U.S. Futures Exchanges Disciplinary Actions Report - November 2017

Posted on: January 3, 2018 By: David Perlman, Michael Brooks, Bob Pease, Jennifer Gordon, Ryan Eletto
The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and is not intended to be a comprehensive review of each and every notice issued. Instead, the report is intended to provide market participants, and compliance personnel in particular, with illustrative examples of rule violations and to bring to light enforcement trends across the exchanges. The disciplinary notices cited in...

U.S. Futures Exchanges Disciplinary Actions Report - October 2017

Posted on: November 28, 2017 By: David Perlman, Michael Brooks, Bob Pease, Jennifer Gordon, Ryan Eletto
The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and is not intended to be a comprehensive review of each and every notice issued. Instead, the report is intended to provide market participants, and compliance personnel in particular, with illustrative examples of rule violations and to bring to light enforcement trends across the exchanges. The disciplinary notices cited in...
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Commodities
Organized Markets

CFTC Annual Enforcement Update

Posted on: November 27, 2017 By: Michael Brooks, David Perlman, George Fatula, Bob Pease, Stephen Hug, Jennifer Gordon, Ryan Eletto
On November 22, 2017, the Commodity Futures Trading Commission (“CFTC”) released its annual enforcement report for fiscal year 2017. As in previous years, this year’s report highlights the agency’s continued commitment to enforcement and aggressive pursuit of those viewed as engaging in conduct that undermines the integrity of CFTC-jurisdictional markets. In fiscal year 2017, the CFTC brought 49 enforcement actions, with matters involving market manipulation, prohibited trading practices, or retail fraud ( e.g ., Ponzi schemes) accounting for the vast majority of these actions (35 out of 49...
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CFTC
Enforcement

FERC Rejects Marketing Affiliate Petition

Posted on: November 27, 2017 By: Ty Johnson, George Fatula, Kirk Morgan, Mark Lewis
Can a marketing affiliate of an oil pipeline purchase transportation at the filed tariff rate and then re-sell this capacity at a lower, non-public rate without running afoul of the Interstate Commerce Act’s prohibition on rebates? On November 22, 2017, the Federal Energy Regulatory Commission (“FERC”) issued an order that addressed this very issue. One year ago, Magellan Midstream Partners, L.P. (“Magellan”) filed a petition for declaratory order at FERC seeking FERC’s opinion on several structures involving a to-be-created marketing affiliate. This marketing affiliate would facilitate...
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FERC
Midstream

FERC Annual Enforcement Update

Posted on: November 20, 2017 By: Michael Brooks, Stephen Hug, Catherine McCarthy, Bob Pease, David Perlman, Sarah Rafie, Serena Rwejuna, Paul Wight
FERC Annual Enforcement Update On November 16, 2017, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) released the Office of Enforcement’s (“OE”) annual report on enforcement activities (“ Annual Report ”) for fiscal year 2017 (“FY 2017”). Although the report, which covers activities from October 1, 2016 through September 30, 2017, merely reflects the activities and views of enforcement staff and is not necessarily representative of the views of the Commission or any Commissioner, the Annual Report can provide useful insights into compliance issues faced by market...
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FERC
Enforcement
Organized Markets

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