Staying In Compliance With New FERC Guidelines

Law360, New York (September 24, 2010, 4:19 PM EDT) -- The Federal Energy Regulatory Commission FERC recently issued revised penalty guidelines based, in part, on industry comments calling for certain changes, such as partial compliance credits, and added a mandatory scienter requirement to assess penalties for misrepresentations or false statements.

On Sept. 17, 2010, the FERC issued its Revised Policy Statement on Penalty Guidelines, following a round of industry comment on the original penalty guidelines issued March 18, 2010.

The original penalty guidelines — which the FERC issued without an opportunity for industry comment — were...
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