The Energy Policy Act of 2005 gave the Federal Energy Regulatory Commission (FERC) increased authority to collect information about natural gas transactions from all market participants. Over the course of the past year, FERC has been working to implement a new reporting requirement, relying on this new authority. The culmination of this effort is Form 552, promulgated and refined in two FERC orders, Order No. 7041 and Order No. 704-A,2 which require certain natural gas buyers and sellers to report annually to FERC information regarding physical natural gas transactions occurring during the prior calendar year.