FERC’s September 17, 2015 notice of proposed rulemaking (NOPR) in Docket No. RM15-23-000 would impose significant information-gathering requirements on participants in markets operated by Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs). The rule would require each market participant to obtain a Legal Entity Identifier (LEI) and to report its LEI and extensive additional information about itself and its Connected Entities to its RTO/ISO who would submit it to FERC. FERC has designed the information requirement, which applies on a regular ongoing basis and must be updated as facts and circumstances change, to reveal direct as well as indirect, third party links between market participants that could afford the incentive and ability to engage in joint action to manipulate and defraud the markets.
Continue Reading FERC Issues Notice of Proposed Rulemaking (NOPR) Regarding RTO/ISO Collection of Uniform Organized Market Participant Data