Capacity market participants have paid millions to FERC in penalties for capacity release rules violations. We can help prevent these penalties.
Compliance audits aren’t just for FERC, financial auditors are requiring CFOs and CROs to quantify and validate their capacity positions and associated risk policies. Many PUCs want independent assurance that LDC capacity release programs meet their criteria and pass a fairness test.
We provide capacity market audits and ongoing compliance monitoring for Shippers, LDCs, Asset Management Companies and Regulatory Agencies. Because we have every capacity release deal ever done in our Capacity Center database, we are uniquely qualified to perform audits and compliance monitoring services.
For testimony or filing purposes, we can also provide third party validation.
Capacity Audit Process
1. We utilize our comprehensive capacity database to review all of your capacity transactions for a defined period of time, regardless of the entity to which it was assigned
- We maintain data on all the shippers and their corporate relationships
2. We compare our records to your internally generated records to provide an Audit Report, including:
- Any side dealing, flipping, or other behaviors that are in violation of FERC Market Oversight and FERC Enforcement rules
- Compliance with “Shipper Must Have Title” rules
- Internal reporting gaps in your records and reasons for gaps
- Detailed issues log
3. Documentation and business process review of your business practices and reporting
- Findings Report
- Recommendations
4. Review session with CFO, CRO, and internal parties
5. Change implementation assistance as requested
Compliance Monitoring
Upon completion of the initial capacity audit, we can provide ongoing compliance monitoring services. On a monthly or quarterly basis, we can:
- Compare internal capacity transaction and position reports to benchmark and validate them against our comprehensive database
- Search for and identify any incidences of potential compliance violations and report them to the company’s designated Risk or Oversight person
- Provide guidance to assure compliance is maintained and penalties avoided
- We also offer independently created data sets for your own auditors’ use
