MRB Compliance Consulting LLC Announces Chevron Deference Blog

A case for overturning the Chevron Deference - Fallacy at the FERC, MRB Blog Post

Michael R. Berry, Founder of MRB Compliance Consulting LLC (MRB), has announced a limited series blogging post related to the Chevron Deference. 

The initial blog post entitled "Fallacy at the FERC" can be found here: Fallacy at the FERC - MRB Consulting (

"I have decided to point out, in great detail, in a singular case that depicts all that is wrong with the current regulatory construct," Berry said. "This is much more than just one regulator run amok. The acts and actions taken by the many participants throughout the 15-year saga (an allegation of commodity price manipulation e.g., the Houston Ship Channel matter) have undermined the importance of Compliance."

In 2006, BP Products North America, Inc. entered into a Consent Order with the Commodity Futures Trading Commission (CFTC) to settle the regulatory matters related to the manipulation of the price of propane. (See here) In 2007 BP America entered into a Deferred Prosecution Agreement (DPA) with the Department of Justice (DOJ) to settle criminal matters related to the manipulation of the price of propane. (See here)

Mr. Berry was the Head of Compliance at BP North America from 2006-2009 and guided the firm through both the DPA and the CO. Mr. Berry is not a lawyer. 

Source: MRB Compliance Consulting LLC

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