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Enforcement Facts:

On November 17, 2011, FERC issued its Annual Report on Enforcement, describing both public and non-public Enforcement activities, including audits, and the oversight and surveillance work performed by Enforcement to assess the competitiveness and efficiency in the wholesale energy markets. ProComply has written a one-page summary of these activities. Download one-page summary.

Regulatory Advisory:

ProComply Regulatory Advisory: FERC Order No. 712: Natural Gas Capacity Release Rules Overhauled by FERC

See White Papers / FAQs for all downloads.

FREE Demo Course:

Energy Industry Regulatory Primer. Learn more about this short primer DEMO course.

Compliance Programs

Knowing your compliance status is the beginning point for most compliance programs. Having access to the most cost-efficient compliance processes is a key to effective risk-managed compliance.

How can your company ensure its compliance?

Know very well what your compliance challenges are. Most companies have only a superficial notion of how difficult some of the compliance measures are to implement. Resource deployment, unintended consequences from related compliance activities and other organizational obstructions can impede the development of even the best-designed compliance programs.

Review a broad range of compliance program alternatives. In one regard, companies no longer need to model their compliance programs around other industry participants. On the other hand, creating a program from scratch, without input from resources that have created dozens of similar programs is also ill-advised. Utilizing a consultant that has successfully built comprehensive compliance programs that have withstood scrutiny from FERC and NERC is the most practical and productive manner to get the job done.

Dedicate senior management and compliance resources. FERC not only requires that each company appoint a senior manager as a Chief Compliance Officer, they expect the CCO to have adequate resources to ensure that each element of the rules are being addressed as part of the compliance program.

Document the compliance program, in detail! Each company is expected to be able to document their compliance activities as part of their requirement to have a culture of compliance. Having developed broad compliance policies, practices to implement those policies and a history of compliance performance, each company should be able to easily demonstrate that their compliance programs are effective and comprehensive.