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July 28, 2014

Technical Conference on Changes to the Company Registration Process

The FERC held a technical conference on April 16, 2013 to discuss changes to its company registration process. The changes will affect all electronic filings requiring the use of a company registration account, such as eTariff and EQR filings. According to FERC Staff, the changes are intended to give users more control over who can make filings and make the filing process more secure.

The first important change is the addition of an Account Manager to the standard Company ID (CID) credentials. Each company should designate an Account Manager who will act as an administrator for the CID. The Account Manager will have total control over the designation of agents for filings, and will also be able to make filings on behalf of the company. Staff recommended that there be at least two Account Managers to ensure no companies are locked out of the registration and designation process due to an Account Manager being out of the office or leaving the company.

After implementation of the new registration process, the default Account Manager can add other Account Managers. Additional Account Managers will have the same access to the CID. All Account Managers can designate certain agents or "Delegated Filers" to submit filings on behalf of the company. Delegated Filers must be individually eRegistered with FERC prior to being added to a CID. Account Managers and Designated Filers will be able to file eTariffs and EQRs.

The individual responsible for transitioning the company from the old registration process to the new registration process will become the new default Account Manager. It is best if this person is an employee of the company. We recommend that each company's Account Manager also designate a Schiff Hardin representative as an additional Account Manager.

Once the initial transition process is complete, the Account Manager will be the only individual who can file eTariffs or EQRs until he or she designates other filers. FERC Staff expects the transition interface to be available sometime in July or August. A company must already have completed the new registration process in order to file a third quarter EQR.

FERC Staff's Technical Conference PowerPoint presentation is available here.

© 2014 Schiff Hardin LLP

About the Author

Associate

Nicole S. Allen is actively engaged in matters involving investor-owned utilities and their affiliates, electric cooperatives, and interstate and intrastate natural gas pipelines.

202-724-6835

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