On April 16, 2009, the Federal Trade Commission (FTC) issued a Revised Notice of Proposed Rulemaking (RNPRM) seeking comment on a proposed rule that would prohibit market manipulation in the petroleum industry. The FTC is authorized to issue rules regulating manipulative and deceptive conduct made in connection with the wholesale purchase or sale of covered petroleum products pursuant to Section 811 of Subtitle B of Title VIII of The Energy Independence and Security Act of 2007. If adopted, the proposed rule will insert the FTC as a regulator and establish additional legal requirements on persons engaged in trading petroleum products at wholesale. The FTC is soliciting comments on the revised proposed rule through May 20, 2009. Because any violation of the proposed rule could subject the violator to civil penalties of up to one million dollars per violation per day, as well as any additional relief imposed by the FTC under the Federal Trade Commission Act, I thought you might want a heads up. You can contact Vinson & Elkins' lawyers William Vigdor or Armita Schacht for further information regarding the comments process or on the FTC's regulation of market activities in the petroleum industry.