Total Gas & Power North America, Inc. and Therese Tran, a natural gas trading and marketing firm and one of its traders, were charged by the Commodity Futures Trading Commission with attempting to manipulate natural gas monthly index settlement prices during four monthly periods in 2011 and 2012. The firm and trader settled the CFTC’s charges, without admitting or denying any of the Commission’s findings or conclusions, by agreeing to pay a fine of US $3.6 million and a two-year prohibition on certain trading activity. According to the CFTC, TGPNA traded a very high volume of fixed-price natural gas contracts during the last week of September 2011, October 2011, March 2012 and April 2012 without any apparent commercial need. This was done, alleged the CFTC, solely to influence the settlement of TGPNA’s related financial basis and index swaps that were priced off the volume-weighted average price of all reported fixed-price transactions occurring during the month-end periods. In September 2014, the Federal Energy Regulatory Commission issued a notice saying it was also investigating TGPNA, Ms. Tran and Aaron Hall, another TGPNA trader, to assess whether they devised and executed “a scheme to manipulate the price of natural gas in the southwest United States between June 2009 and June 2012.” In its complaint against TGPNA, the CFTC also claimed that the firm's attempted manipulation constituted a prohibited employment of a manipulative device under the Commission's relatively new Dodd-Frank authority.