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Dr. Sharon Brown-Hruska

Vice President

Washington, DC
tel: +1 202 466 9222
fax: +1 202 466 3605



PhD and MA in economics,
BA in economics and international studies,
Virginia Polytechnic Institute


Dr. Brown-Hruska is a Vice President in NERA's Securities and Finance Practice. She is a leading expert in securities, derivatives, regulatory economics, and risk management. Prior to joining NERA, she served as Commissioner (2002-2006) and Acting Chairman (2004-2005) of the US Commodity Futures Trading Commission (CFTC).

Economics Advisory: Dr. Brown-Hruska provides consulting, analysis, and advisory services to various industries, associations, and entities regarding market design and the implications for credit and financial risk management. She has evaluated and advised on the auction rules and processes for the valuation and allocation of reference entity securities underlying Credit Default Swaps. She has analyzed techniques and innovations in clearing mechanisms for operational and counterparty risk management in the over-the-counter (OTC) derivatives markets. As an expert for the largest swap-trading facility in interest rate and credit default swaps, Dr. Brown-Hruska analyzed the cost of using different approaches to calculate collateral for margin and regulatory capital requirements for buy-side users of cleared swap contracts. She has also compared and evaluated various markets (exchange and OTC) and auction mechanisms for differences in market quality and their susceptibility to manipulation.

Financial Markets and Information: Dr. Brown-Hruska is an expert on financial markets and how changes in regulation, market structure, and information technology can affect measures of market quality (including liquidity, risk, and price efficiency). She has published various articles and reports on market transparency and the proprietary nature of market information, and has opined on the trading strategies of market makers and how changes in market structure have affected their operation and the efficiency of the markets. As Chairman of the CFTC's Technology Advisory Committee, she directed consideration of intellectual property in trading and settlements technology, the usage of exchange settlement prices in OTC markets, and the regulatory implications of electronic trading.

Energy: Dr. Brown-Hruska provides consulting and advice on energy markets, energy trading, and their regulation. She has spoken on energy issues to many forums and organizations, including the Energy Bar Association, Edison Electric Institute, and the World Forum on Energy Regulation. She has published articles in the Energy Daily on energy derivatives and in the Futures and Derivatives Law Report on market manipulation in the energy markets. She was awarded the Key Women in Energy's Global Leadership Award in March 2004, announced at the National Energy Marketers Association Conference in Washington, DC.

Regulation: Dr. Brown-Hruska served as a member of the President's Working Group on Financial Markets, with the Secretary of the Treasury, Chairman of the Federal Reserve Board, and the Chairman of the Securities and Exchange Commission. She testified on the function and regulation of the US futures and options markets before the US Senate Committee on Agriculture, Nutrition, and Forestry, and the House Subcommittee on General Farm Commodities and Risk Management. She has addressed numerous governmental, financial organizations, and associations, including the International Monetary Fund, Structured Products Conference, Managed Funds Association, Futures Industry Association, Securities Industry Association, Bond Market Association, and the International Swaps and Derivatives Association.

International: Dr. Brown-Hruska participated in high level international meetings with members of the European Commission, the Committee of European Securities Regulators (CESR), the International Organization of Securities Commissioners (IOSCO), and various other governmental and regulatory organizations. She initiated the Transatlantic Cooperation Initiative to identify practical solutions to regulatory challenges in the cross-border derivatives business. She presided over the Joint Meeting of the CFTC and the CESR to Facilitate Transatlantic Business in Paris, and addressed the IOSCO Technical Committee in Frankfurt and New York. Her articles in the area of international regulation have been published in Revue bancaire et financière, International Commodities Review, and Swiss Derivatives Review.

Enforcement: Dr. Brown-Hruska issued separate opinions in adjudicatory matters where the decisions could be detrimental to the conduct of business and in the markets regulated by the CFTC. In Hussain, she argued against a standard that viewed a brokerage firm's efforts to liquidate the margin account of a defaulting customer as a form of unauthorized trading. In Man Financial, she challenged the assumption that omissions absent deceit should be construed as a breach of a fiduciary that rose to the level of fraud. In Nikkhah, Miller, R&W, Gorski, and Staryk, she emphasized the importance of economic methods to achieving deterrence in determining civil monetary penalties. In Gorski, she urged the CFTC to be more open to the use of tools derived from economic analysis, and to strive to complement institutional knowledge of trading practices with empirical techniques for evaluating and interpreting market information that impart greater objectivity and weight to the evidence.

Derivative and alternative assets: Prior to her public service, Dr. Brown-Hruska was an Assistant Professor of Finance at George Mason University (1998-2002) and at Tulane University (1995-1998) specializing in derivative and alternative asset markets. Her articles have appeared in Capital Markets Law Review, Barron's, the Journal of Futures Markets, and the Review of Futures Markets. She holds a PhD and MA in economics and a BA in economics and international studies from Virginia Tech in Blacksburg, Virginia.