In 2013 alone, the FERC levied $445 million in civil penalties and disgorgements. Operating under its authority under Dodd-Frank laws and FERC 670, FERC is taking an aggressive stance on market manipulation and related misbehaviors. Staying in compliance often involves the use of ETRM software systems used to house energy transactions such as Allegro, Triple Point, Openlink, SAS BookRunner, Solarc, Sungard, and other products. Gelber maintains expertise to get the most out of these software systems so they function optimally and better keep your firm in compliance (see Technology section for more information).
Companies must get themselves into the position of self-reporting problems before they are discovered by regulators. When companies self-report and take voluntary corrective action, penalties and disgorgements are a mere fraction of the amounts levied otherwise. This is true in electric power, transmission and congestion markets, as well as natural gas and transportation markets. Whether your entity trades physically or financially, you will want to speak with Gelber's Compliance team. This is more true should you trade around assets owned by your organization in which the FERC may perceive you to have additional market manipulating abilities.
Gelber has remained on the cutting edge of the Best Practices for power, natural gas, crude oil and oil products, and regulatory compliance. Our 25 years in the energy business plus our unique independent positioning has given us the expertise and ability to perform a best practices review, provide recommendations, and implement those recommendations.
SERVICES MAY INCLUDE:
- GAP Analysis
- Staff & Management Education
- Self-Reporting Decision Review
- FERC Legal Consulting (FERC 670)
- Government Reporting and Outsourcing
- Up to Congestion (UTC) Business Practice Limitation at Owned Interconnect/Nodes/Hubs
- Bookout Compliance and Reporting Review
- Physical Swap Data Record Keeping and Reporting Requirements
- Embedded Trade Option Identification, Valuation, and Reporting