Matt Connolly, a senior associate in Nutter’s Litigation Department, discussed the Federal Energy Regulatory Commission (FERC) issuing its first enforcement order since regaining a quorum in Nutter Insights. Matt commented on what the case, FERC v. City Power Marketing, LLC, entails; the key terms of the settlement; and if this settlement suggests a shift in priorities or trends for FERC. According to Matt, FERC has previously rigidly applied its Penalty Guidelines to entities in market manipulation cases, rarely deviating unless a defendant shows financial hardship. That may be changing.