Cornerstone Research has extensive experience in handling Commodity Exchange Act (CEA) disputes, enforcement, and commercial litigation. Our team delivers rigorous economic analysis and expert testimony to support clients in regulatory investigations, enforcement actions, and litigation. Through close collaboration with clients, including outside counsel, government agencies, and in-house counsel, we develop targeted economic arguments and strategies that address our client’s unique needs, whether in regulatory proceedings, civil or criminal litigation, or internal investigations.  CEA disputes typically involve complex issues related to the trading and regulation of commodities and financial derivatives such as futures, options, or swaps. Our seasoned staff and experts bring expertise in commodity futures trading. We are adept at navigating matters with allegations of market manipulation, price fixing, fraud, insider trading, breach of contract, or violations of trading rules. We provide detailed economic analysis to assess market behavior, trading patterns, pricing trends, and the economic impact of alleged misconduct, ensuring our clients receive expert support in their regulatory or litigation needs.  

Our experience includes: 

  • Investigating allegations of market manipulation, false reporting, and price manipulation in commodities with related physically settled futures markets. This includes assessing allegations of corners, squeezes, and market power. 
  • Applying our extensive experience in the delivery procedures on physically delivered futures contracts involving shipping certificates and warehouse receipts. 
  • Analyzing alleged spoofing and other disruptive trading activities.  
  • Examining front-running allegations and pre-hedging practices. 
  • Evaluating alleged benchmark manipulations, banging the close, and other manipulations of settlement indices.  
  • Analyzing alleged misreporting of trade information and its potential price impact. 
  • Evaluating trading and hedging strategies. 
  • Working on alleged market power, collusion, and other antitrust investigations and litigation related to various commodities and futures markets. 
  • Working on matters involving crude oil, natural gas, electric power, refined petroleum products, ethanol, cattle, poultry, hogs, dairy, wheat, cotton, coffee, oilseeds, and metals, among others.
  • Preparing summary materials and presentations to regulators at the Commodity Futures Trading Commission (CFTC), to Self-Regulatory Organizations (SROs) such as the National Futures Association (NFA), and to futures exchanges such as the CME Group and ICE Futures U.S. 
  • Assessing swap agreements as part of an International Swaps and Derivatives Association (ISDA) dispute. 
  • Conducting derivative valuation techniques for futures, options, and swaps. 
  • Working with multinational commodity merchandisers, trading platforms, and intermediaries.  

Featured Experts

Featured Experts

Terrence Hendershott

Professor and Willis H. Booth Chair in Banking and Finance,
Haas School of Business,
University of California, Berkeley

Terrence “Terry” Hendershott is a recognized authority on market microstructure, market manipulation, and the structure of financial markets. Professor Hendershott’s academic research focuses on financial market design, structure, and competition; and how the activities of market participants affect price discovery and liquidity. He is an expert on a range of financial instruments, trading both on exchanges and over the counter. Professor Hendershott’s research has been published in leading academic journals and has received numerous awards.

Professor Hendershott has extensive testifying experience, including in depositions, arbitrations, and trials. He has provided testimony in cases involving a wide range of market microstructure issues. He has analyzed claims related to market manipulation and disruptive trading, high-frequency and algorithmic trading, trading execution, financial market design, as well as market efficiency and price discovery.

In the context of antitrust litigation, securities litigation, regulatory enforcement actions, and commercial disputes, Professor Hendershott has addressed class certification, loss causation, and damages issues. His consulting and testifying experience encompasses U.S. and international financial markets, including equities, exchange-traded funds, corporate and government debt, commodities, foreign exchanges, futures, and other products.

In his academic research, Professor Hendershott examines the design, regulation, and structure of stock exchanges, electronic communications networks, and over-the-counter markets. He has analyzed how different market participants, such as market makers, high-frequency traders, and institutional investors, affect price discovery and liquidity. In that context, he has also analyzed the interplay of and competition between electronic and traditional markets, as well as the role of information technology.

Professor Hendershott has received numerous honors for his research. These include the Michael J. Brennan Award for the best paper published in the Review of Financial Studies; the New York Stock Exchange best paper on equity trading, awarded by the Western Finance Association; the Outstanding Publication Award from the Financial Review; and the NASDAQ Award for the best paper on market microstructure, awarded by the Financial Management Association International. He has served as an associate editor for the Journal of Financial EconomicsManagement Science, the Journal of Financial Markets, and Information Systems Research.

Professor Hendershott chaired the NASDAQ Economic Advisory Board and served as a visiting economist at the NYSE.

Featured Experts

James A. Overdahl

Former Chief Economist,
Former Director, Office of Economic Analysis,
Securities and Exchange Commission;
Former Chief Economist,
Commodity Futures Trading Commission

James Overdahl is an authority on financial and commodities markets, financial regulation, and securities. His areas of expertise include exchange-traded futures and options, over-the-counter (OTC) derivatives, algorithmic trading, risk management, and short selling.

Dr. Overdahl has testified in complex securities litigation, including matters involving alleged insider trading, market manipulation, and false reporting. He has analyzed class certification, loss causation, and damages in numerous securities class actions. In addition, Dr. Overdahl has significant experience assessing price and volume integrity issues in the context of cryptocurrency exchanges.

For more than three decades, Dr. Overdahl served at U.S. regulatory agencies, including the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and the Office of the Comptroller of the Currency (OCC).

As chief economist and director of the Office of Economic Analysis at the SEC, Dr. Overdahl oversaw the Commission’s economic analysis in all areas of policy, rulemaking, and enforcement. He advised on policy and rulemaking related to credit default swaps (CDS) and other OTC derivatives, OTC clearing, algorithmic trading, and securities lending.

Dr. Overdahl has testified before Congress on behalf of the SEC and CFTC. Since leaving government service, he has worked as a consulting expert and appeared before the staff of these agencies on numerous matters.

Widely published, Dr. Overdahl has contributed articles to leading economics and finance journals, including the Journal of Business, the Journal of Law and Economics, and the Journal of Financial and Quantitative Analysis. He is the coauthor of several books on financial derivatives and futures markets, all of which have been reprinted in multiple editions.

Dr. Overdahl has served as an adjunct professor of finance at the George Washington University, the University of Maryland, Johns Hopkins University, Georgetown University, Virginia Tech, and George Mason University.

Featured Cases and Publications

16 July 2024

Characteristics of U.S. Natural Gas Transactions

Cornerstone Research compiles an annual report based on data from FERC Form 552 submissions. By supplementing the data with proprietary classificat...

10 June 2022

From Zero to 100: Crude Oil Price Changes in 2020–2022

This article provides analysis of the market microstructure implications of oil futures and spot prices for market participants.

5 May 2020

“Contango With Me”: COVID-19 and the U.S. Crude Oil Market

This article looks at how the COVID-19 pandemic's effect on crude oil storage in the United States.

19 September 2013

Market Microstructure

Our work in this area has included numerous issues related to order handling, allegations of front running, rules involving price quoting, clearing...

17 September 2010

Economic Benefit of the Trading Activity

In evaluating damages, the gains realized (or losses avoided) from the alleged trading activity are generally considered by the court.

25 September 2009

Other Market Manipulation Experience

Cornerstone Research has played active but nonpublic roles in a wide range of energy-related litigation and investigations.

Selected Professionals