Company Registration System

Introduction to the Company Registration System and depository trust company direct registration profile system
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FEDERAL ENERGY REGULATORY COMMISSION Secretary of the Commission Instructions for Company Registration Version: November 7, 2016 FERC-545, OMB Control No. 1902-0154 FERC-549, OMB Control No. 1902-0086 FERC-550, OMB Control No. 1902-0089 FERC-920, OMB Control No. 1902-0255 Public Instructions for Company Registration 2 Table of Contents Summary ................................................................................................... 1 Introduction to the Company Registration System ...................................... 5 The Company Registration Process ............................................................ 8 1) What information must I submit for Company Registration? .............. 8 2) Options Page (Options Page) ........................................................... 9 a) Registering a New Company ........................................................... 9 b) Transitioning .................................................................................... 9 c) Managing a Company Profile ........................................................... 9 3) Information Page (Information Page) ................................................ 9 a) Company Name ............................................................................... 9 a) My company is a Required Filing Company. What should I enter as my company’s name? .................................................................. 9 b) My company is a Required Filing Company. How should I determine which company name to use if my company has affiliates? ......................................................................................... 10 c) What official name should I use for my Required Filing Company? ...................................................................................... 10 d) Can I register a holding company as a Required Filing Company? ...................................................................................... 11 e) What should I do if my Required Filing Company Name changes? ........................................................................................ 11 f) My company is a Delegated Filer. What company name should I use? ................................................................................................ 11 g) My company is a Delegated Filer. What should I do if my Company Name changes? .............................................................. 11 b) Company Address ......................................................................... 12 c) Official Company Email Address.................................................... 12 d) Official Company Website .............................................................. 12 e) Effective Date ................................................................................ 13 a) What Effective Date should I enter if I am registering my company for the first time? .............................................................. 13 b) What Effective Date should I use if I am updating my company’s Company Profile? ........................................................................... 13 4) Regulatory Programs ...................................................................... 13 a) Who must choose a Regulatory Program? .................................... 14 b) If my company is a Public Utility under the Federal Power Act, which program option should I select? ........................................................... 14 Public Version: November 14, 2016 Instructions for Company Registration 3 c) If my company is a Hinshaw pipeline, which Regulatory Program should I select? .................................................................................... 15 d) Under what Regulatory Program should I register if my company is not a public utility but also is not a Power Administration? ................... 15 e) What should I do if my company needs to register under multiple Regulatory Programs? ......................................................................... 15 Assignment Page (Assignment Page (CID version)); (Assignment Page (DID version)) ........................................................................................... 16 1) Form Selection ................................................................................ 16 a) Will a Required Filing Company’s decision not to register or select a Form be construed as a petition for waiver of its obligation to file a particular Form? ................................................................................... 16 2) Account Managers .......................................................................... 16 a) What are the responsibilities of an Account Manager? .................. 16 b) Who is initially appointed as Account Manager? ............................ 17 c) Can I select a Delegated Filer or a Required Filing Company to be an Account Manager? .......................................................................... 17 d) How do I assign Account Managers? ............................................. 17 e) How do I remove Account Managers? ........................................... 17 f) How many Account Managers should my company choose? ........ 18 g) Are Account Managers able to file Forms? .................................... 18 h) Do Delegated Filers need Account Managers? .............................. 18 i) Does Commission Staff Review the Assignment of Account Managers? ........................................................................................... 18 3) Agents ............................................................................................ 18 a) What people or entities can be designated as an Agent? .............. 18 b) How do I assign my company’s first Agent? ................................... 20 c) How do I assign Agents? ............................................................... 20 d) How do I delete Agents? ................................................................ 20 e) What are the filing rights of Delegated Filers assigned as Agents? 20 f) Can Delegated Filers assign Agents for specific Required Filing Companies? ........................................................................................ 20 g) Can a Required Filing Company select one of its affiliates as an Agent? ................................................................................................. 21 h) Does Commission Staff Review the Assignment of Agents? ......... 21 How will I know if my Company Registration or modification of my Company Profile was successful? ............................................................ 21 Concluding the Company Registration Process ........................................ 22 Public Version: November 14, 2016 Instructions for Company Registration 4 1) My company is a Required Filing Company registering for the first time. What happens after I successfully submit my new Company Registration request? ............................................................................. 22 2) My company is a Required Filing Company with an existing Company Identifier. What happens after I successfully submit my request to transition to the new Company Registration system? ......................... 22 3) My company is a Delegated Filer. What happens after I successfully submit my Company Registration request? ............................................ 22 APPENDIX A: SCREEN SHOTS AND ADDITIONAL INSTRUCTIONS .... 23 1) Options Page .................................................................................. 23 2) Information Page ............................................................................. 24 3) Assignment Page (CID version) ...................................................... 25 4) Summary Page ............................................................................... 27 5) Confirmation Page .......................................................................... 28 6) Transitioning an Existing Company to the New Company Registration System ............................................................................... 29 7) Modifying a Company Profile .......................................................... 30 8) Using the “Assignment to Forms and CID Account Managers” Function ................................................................................................. 32 a) How do I assign additional Account Managers?............................. 33 Select the correct email address (the typed entry will not work, as the system must capture data associated with the eRegistered email address not visible on the screen), then click the “Appoint Account Manager” button to add that person as an Account Manager. .............. 33 b) How do I assign additional eRegistered persons as Agents? ......... 34 c) How do I assign additional Delegated Filers as Agents? ................ 34 APPENDIX B: Acquiring Full eRegistration ............................................... 35 APPENDIX C: Company Registration Email Templates ............................ 37 APPENDIX D: Related Paperwork Reduction Act Information .................. 44 Public Version: November 14, 2016 Instructions for Company Registration 5 Introduction to the Company Registration System What is a Company Identifier (CID)? A Company Identifier (CID) is an identification number assigned to a company that is required by Commission regulations to submit an electronic filing using a Company Identifier. What is a Required Filing Company? A Required Filing Company is a company that must obtain a Company Identifier to make certain filings with the Commission. In this instruction manual, Required Filing Companies are also referred to as Required Filers. Who must obtain a Company Identifier (CID)? You must obtain a Company Identifier if your company is required by Commission regulations to submit an electronic filing for which a Company Identifier is required. If you are uncertain about whether an electronic filing you are required to submit requires a Company Identifier, you should obtain legal advice regarding FERC regulatory affairs and, if deemed necessary, consult with appropriate FERC staff. Do all electronic filings require a Company Identifier? No. Not all electronic filings require the use of a Company Identifier. The requirement applies to filings of tariffs and those forms for which the Commission has explicitly required the use of a Company Identifier. The Commission may expand the types of filings for which a Company Identifier is required. Is there a deadline by which a company must register? A company must register prior to making its first electronic filing that requires a Company Identifier. How long will it take to obtain a Company Identifier? Requests for Company Identifiers are processed by FERC staff. You should expect a two (2) business day delay from the time a request is made to the time you receive your Company Identifier. There may be a further delay if you simultaneously make numerous requests for Company Identifiers and/or modifications thereof. Incomplete or questionable data entries may also result in a delay in the issuance of your Company Identifier, or may result in the rejection of your request. If my company completes Company Registration and obtains a Company Identifier, does that mean my company is a regulated entity? Public Version: November 14, 2016 Instructions for Company Registration 6 No. Company Registration and acquiring a Company Identifier permits a company to make certain electronic filings with the Commission. In other words, Company Registration is simply a precondition for making certain electronic filings with the Commission. Various statutory, regulatory, and Commission findings determine whether a company is a regulated entity. Will my Company Identifier be available to the public? Yes. Is my company registered? The Commission posts a list of registered Required Filing Companies on its web site, www.ferc.gov, for each Industry under the Required Filing Companies link. These lists may not be current. If your company name cannot be found on the lists, please send an inquiry to ferconlinesupportferc.gov. Your inquiry should include the name of the company at issue and what Regulatory Program it should be part of. Can I have multiple Company Registrations for the same company? Not in the same Regulatory Program. Do not attempt to re-register a company that is already registered in a Regulatory Program. Multiple registrations may cause significant administrative, tariff, and compliance issues for your company. Also, FERC staff are likely to reject multiple registration attempts. What is a Delegate Identifier (DID)? A Delegate Identifier (DID) is an identification number for a company that makes filings on behalf of a Required Filing Company. Such a company may want to obtain a DID in order manage its own Account Managers and Agents. For example, some Required Filing Companies may prefer that law firms or electronic vendors submit filings on their behalf, and that those law firms or vendors determine which of their individual employees will do so. Such law firms or vendors may want to obtain a Delegate Identifier so they will have the capability to assign their individual employees as Account Managers and Agents. What is a Delegated Filer? A Delegated Filer is a company that has obtained a Delegate Identifier and, therefore, can be assigned the authority to make filings on behalf of a Required Filing Company. Before a Delegated Filer can submit filings on behalf of a Required Filer, the Required Filer must login to the Company Registration system, select the Delegated Filer, and then assign it the authority to make the desired required filing(s). Why would a company want to obtain a Delegate Identifier (DID)? Public Version: November 14, 2016 Instructions for Company Registration 7 A company would want to obtain a DID if a Required Filing Company wants to delegate the company (rather than individuals) to make filings on the Required Filing Company’s behalf. The Delegated Filer would then be able to manage its own account and assign Account Managers and Agents. Must a company that makes filings on behalf of a Required Filing Company obtain a Delegate Identifier (DID)? There is no regulatory requirement that a company that acts as a Delegated Filer must obtain a Company Registration account. DID accounts are simply a service offered by the Commission. However, without such an account, the Required Filer could not select the Delegated Filer company to make filings on its behalf, but could still select individual persons at that company to submit filings on the Required Filer’s behalf, after designating those individuals as Agents. Can members of a law firm or vendor make filings on behalf of a Required Filing Company without obtaining a Delegate Identifier? Yes. The Required Filing Company would have to designate the specific members of the law firm or vendor as either Agents or Account Managers. Can a Required Filing Company, using a CID, also be a Delegated Filer? No. If a Required Filing Company wishes to be a Delegated Filer for another company, it should request a DID. How long will it take to obtain a Delegate Identifier (DID)? This will occur immediately upon completion of the Company Registration process. Unlike applications for Company Identifiers (CID), applications for Delegate Identifiers are automatically approved; i.e., they are not reviewed by FERC staff. When must a company obtain a Delegate Identifier (DID)? There is no deadline by which a company must obtain a Delegate Identifier number. However, a company must obtain a Delegate Identifier before it can be selected as a Delegated Filer by a Required Filing Company. Public Version: November 14, 2016 Instructions for Company Registration 8 The Company Registration Process 1) What information must I submit for Company Registration? The Company Registration system consists of three sequential web pages, which can be described as the Options Page, the Information Page, and the Assignment Page. The information set associated with the Company Identifier is referred to as the Company Profile. The information needed to complete these pages should be assembled prior to entering the Commission’s Company Registration web page to reduce the chances of timing out. Details on each category of information are provided below. (Screen shots are at Appendix A and can be found by following the hyperlinks below.) 1) The Options Page (Options Page) is where you select the reason you are logging into the Company Registration system. There are three reasons: a) to register a new company b) to transition an existing Company Identifier from the old system to the new system c) to manage your Company Profile (after you have already completed Company Registration). 2) The Information Page (Information Page) After selecting the applicable option on the Options Page, you will be required to submit information on the information page. The specific information required on the Information Page is: a) Whether you are registering as a Required Filing Company or a Delegated Filer b) Company Name c) Company Address d) Official Company Email Address e) Official Company Website (optional for Delegated Filers) f) Effective Date g) The Regulatory Program under which your filings are required. 3) The Assignment Page (Assignment Page CID) (Assignment Page DID) The following information is required to complete the Assignment Page: a) Forms you are required to file under the selected Regulatory Program b) Who you would like to designate as Account Managers and Agents to submit filings for your company. Public Version: November 14, 2016 Instructions for Company Registration 9 Specific Issues related to filling out the Options Page, Information Page and Assignment Page are discussed below. 2) Options Page (Options Page) a) Registering a New Company This option will enable a company that has not previously registered for a Company Identifier (CID) or a Delegate Identifier (DID) to complete the Company Registration process and obtain a CID or DID. b) Transitioning Transitioning applies only to companies that previously were registered in the Company Registration system. The transition process will enable them to easily move to the new system while retaining their existing Company Identifier (CID) number. c) Managing a Company Profile This option will enable the company to change or revise the information on the Information Page and the Assignment Page. 3) Information Page (Information Page) a) Company Name a) My company is a Required Filing Company. What should I enter as my company’s name? If you are registering a Required Filing Company, your Company Name should be the name of the company that is, or will be, subject to filing requirements pursuant to the statutory and regulatory requirements of the Program for which the company is registering. If you are registering a Delegated Filer, your Company Name should be the name of the company to which the Required Filing Company has delegated its filing authority. Public Version: November 14, 2016 Instructions for Company Registration 10 b) My company is a Required Filing Company. How should I determine which company name to use if my company has affiliates? Your Company Name should be the name of the company that is, or will be, subject to filing requirements pursuant to the statutory and regulatory requirements of the Program for which the company is registering. For example, XYZ Company is a Natural Gas Act (NGA) natural gas pipeline company that is also a subsidiary of ABC Holding Company. XYZ Company wishes to register under the Commission’s NGA program, which imposes an eTariff electronic filing requirement. When XYZ Company is completing its Company Registration to obtain the Company Identifier necessary for the company to make its eTariff filings, the Company Name entered should be XYZ Company, as that is the FERC-regulated entity under the NGA program. As an additional example, take a company, MNO Public Utility, LP, that has two operating divisions: MNO Public Utility (New Mexico), division of MNO Public Utility, LP, and MNO Service Company, division of MNO Public Utility, LP. The only company that is required to file is MNO Public Utility, LP, not the individual operating divisions; therefore, “MNO Public Utility, LP” should be the company name entered when MNO Public Utility, LP is completing its Company Registration. c) What official name should I use for my Required Filing Company? Your Company Name should be exactly as shown on your articles of incorporation. No “doing business as”, dba, d/b/a, or other pseudonym Company Names are permitted. Do not use abbreviations or acronyms that are not part of the name shown on the articles of incorporation. (For example, do not enter “PGT” or “Pacific Gas Trans. Corp.” when the full name may be “Pacific Gas Transmission Corporation”.) In the Commission’s experience, the most common electronic filing mistake is misspelling the Company Name. Your Company Name should be properly spelled and should include any contractions, commas, periods, or the lack thereof, that are present in the company’s name as it appears on its articles of incorporation. (For example, be specific about whether your company name includes “Incorporated” or “Inc.”, “LLC” or “L.L.C.”, etc.) Public Version: November 14, 2016 Instructions for Company Registration 11 The registration form provides space for 250 characters for a Company Name. Some FERC applications that utilize this data will, for technical reasons, truncate the Company Name from right to left. d) Can I register a holding company as a Required Filing Company? No. Only the company required to make the filing can register as the Required Filing Company. e) What should I do if my Required Filing Company Name changes? Changing a registered Company Name is permitted through the Company Registration web site. Changing the Company Name through Company Registration is the only means of informing the Commission of (1) a name change for a Required Filing Company, (2) any change to the Company Name that will appear on electronic filings that require the use of a Company Identifier, and (3) any change to the Company Name shown on the public version of a company’s eTariff maintained by the Commission. HOWEVER, Required Filing Companies should use extreme caution before proceeding with a name change. There are numerous additional regulatory requirements and business practices associated with changing the name of a Required Filing Company. A company should obtain legal advice regarding FERC regulatory affairs and, if deemed necessary, consult with appropriate FERC staff before changing the Company Name in the Company Registration system. Incorrect or untimely name changes can have unpredictable regulatory and legal consequences. f) My company is a Delegated Filer. What company name should I use? There is no specific requirement for company names for Delegated Filers. These names will not be checked by FERC staff. We encourage the use of the official name of the company or law firm, rather than abbreviations or acronyms. g) My company is a Delegated Filer. What should I do if my Company Name changes? Public Version: November 14, 2016 Instructions for Company Registration 12 You should change your Company Name in the Company Registration system. However, you should be aware that such a change in the Company Registration system will not affect company names on service lists. b) Company Address Your Company Address should be the street address of your company’s primary place of business. c) Official Company Email Address Your Official Company Email Address should be carefully chosen. This email address will be used by the Commission to inform a company of electronic filings made using that company’s Company Identifier. Personal email addresses often become inaccessible to a company over time and, therefore, should not be used as the Official Company Email Address. The Official Company Email Address will populate the Commission’s service list for those filings that require service lists. d) Official Company Website If your company is a Required Filing Company, you must provide the URL address of your company’s official website. If your company has several web addresses, the URL that you provide should be for a site that clearly leads to your Required Filing Company’s informational postings similar to those required 2 by North American Energy Standards Board’s (NAESB) Standard 4.3.23. If your company is not yet a Required Filing Company, but is seeking to become one, you should enter a URL address that can be used to cross-check the accuracy of the other required Company Registration data. Once your company obtains a Company Identifier, your company should, or must (depending on the requirements of the Regulatory Program), update the URL address in the Company Registration system. A Delegated Filer is not required to provide a company website. If you choose to do so, you should provide the URL address of the company website most relevant to the filings you will be making. 2 NAESB Standard 4.3.23 provides the minimum informational categories for web-based informational postings. Public Version: November 14, 2016 Instructions for Company Registration 13 e) Effective Date The Effective Date is the date on which you want your proposed changes to Company Registration to become effective. When entering the Effective Date, you should consider whether you are registering your company for the first time or updating your company’s Company Profile. Retroactive dates are not accepted. a) What Effective Date should I enter if I am registering my company for the first time? The Effective Date for a new Company Registration will default to the date the data is entered. This will permit your company to make an electronic filing (requiring the use of a Company Identifier) with the Commission as soon as your company receives its Company Identifier. You can propose a prospective Effective Date, but you should be aware that your company will not be able to use its Company Identifier to make an electronic filing until the Effective Date. b) What Effective Date should I use if I am updating my company’s Company Profile? You should enter the date that on which you would like the updated information to be reflected in the Commission’s records. For Required Filing Companies, updated Company Profiles become effective on either the proposed Effective Date or the date the proposed change to the Company Profile is approved by FERC staff, whichever occurs later. Proposed effective dates cannot be retroactive, since companies cannot propose retroactively to revise the names of their tariffs, change data that is obtained from the Company Profile to be associated with past electronic filings, revise Notices to the public, revise service lists, or change the official record in eLibrary. 4) Regulatory Programs Regulatory Programs refer to the Commission’s different statutory mandates and regulatory schemes. In broad terms, there are six (6) programs: 1) Public Utilities under the Federal Power Act with only Electric Market- Based Rates; 2) Public Utilities under the Federal Power Act other than those that are solely Market-Based Rate Filers 3) Power Administrations under the Flood Control Act, the Bonneville Power Act, the Northwest Power Planning Act, and other relevant statutes; 4) Natural Gas Companies under the Natural Gas Act; Public Version: November 14, 2016 Instructions for Company Registration 14 5) Intrastate Pipelines under the Natural Gas Policy Act of 1978 and Hinshaw pipelines under the Natural Gas Act; and 6) Oil Pipelines under the Interstate Commerce Act. a) Who must choose a Regulatory Program? Every Required Filing Company must select one Regulatory Program. All filings made by that company under the provided Company Identifier will be processed by the Commission consistent with the statutory, regulatory and business rule requirements of that Regulatory Program. For example, if an entity is registered as a public utility under the Federal Power Act, and the entity attempted to make a Natural Gas Act tariff filing, that tariff filing would be rejected because the entity is not a natural gas company. You should select the Regulatory Program that best describes the statutory authority under which your Required Filing Company is required to submit electronic filings to the Commission. b) If my company is a Public Utility under the Federal Power Act, which program option should I select? Public utilities are provided two program options: (i) public utilities with ONLY market-based rates; and (ii) public utilities with other filed tariffs, such as transmission OATTs, cost-based rates, etc.  Public utilities with ONLY market-based rates: as the title itself indicates, you should select this option only if your company has only market-based rates.  Public utilities with additional tariffs: you should select this option if your public utility has a transmission tariff, OATT, cost-based rate or any tariff other than a market-based rate tariff. ISOs and RTOs should select this option. Companies choosing this option also can include their market- based rate tariff. If your public utility has only market-based rates but wishes to propose, or is required to offer, cost-based rates, you must modify your Company Registration information to reflect the change. This modification of your Company Registration information will not result in a new Company Identifier. Public Version: November 14, 2016 Instructions for Company Registration 15 c) If my company is a Hinshaw pipeline, which Regulatory Program should I select? Natural Gas Companies who are subject to section 1(c) of the NGA (Hinshaw pipelines) are subject to the same Commission business processing rules that apply to intrastate pipelines under the NGPA. Therefore, Hinshaw pipelines should register under the same Regulatory Program as NGPA intrastate pipelines, rather than under the NGA Regulatory Program. d) Under what Regulatory Program should I register if my company is not a public utility but also is not a Power Administration? You should register as a public utility. Such registration is for FERC’s administrative purposes only and will not change your company’s status. If your entity is a Non-Public Utility that is required to file an EQR but not an 3 eTariff, you should select the public utilities with cost-based rates option. Your selection of this option is purely for the Commission’s administrative purposes and provides no indication as to how Non-Public Utilities set their rates. e) What should I do if my company needs to register under multiple Regulatory Programs? If your company is required to submit electronic filings (requiring under a Company Identifier) under two or more of the Commission’s Regulatory Programs, you must complete the Company Registration process separately under each program. Different Company Identifiers will be issued for each registration. 3 A Non-Public Utility is a market participant with more than a de minimis market presence that is exempted from the Commission’s jurisdiction by section 201(f) of the Federal Power Act. 18 C.F.R. § 35.10b (effective October 12, 2012). However, excluded from this definition are entities engaged in purchases or sales of wholesale electric energy or transmission services within the Electric Reliability Council of Texas or any entity that engages solely in sales of wholesale electric energy or transmission services in the states of Alaska or Hawaii. Id. Public Version: November 14, 2016 Instructions for Company Registration 16 Assignment Page (Assignment Page (CID version)); (Assignment Page (DID version)) 1) Form Selection The Forms list represents all of the Forms that are required to be submitted under the Regulatory Programs that require electronic filings using a Company Identifier. Only Required Filing Companies can, and must, select Forms; Delegated Filers do not have the option to select Forms. To the left of each Form is a checkbox. To the right of some Forms is a drop- down menu with additional sub-options. You must select the checkbox for every Form that is required under the Regulatory Program associated with your Company Identifier. a) Will a Required Filing Company’s decision not to register or select a Form be construed as a petition for waiver of its obligation to file a particular Form? No. Failure to register or select a Form does not constitute a petition for waiver of a filing obligation. Requests for waiver of the requirement to file a Form must be made with the Commission consistent with the requirements of Part 385 of the Commission’s regulations, not through the Company Registration application. A Required Filing Company must select a Form as required even if the Required Filing Company has received a waiver of its obligation to file the Form from the Commission. Selecting a Form as required is only an indication that a Required Filing Company is subject to filing the Form, not that a Form is required to be filed for any given reporting period. 2) Account Managers An Account Manager is the eRegistered name of a person to whom your company wishes to grant account management rights over your Company Registration account. a) What are the responsibilities of an Account Manager? An Account Manager has control over your Company Registration account. Each Account Manager has the ability to change your company information, add or remove other Account Managers, add or remove Agents, and assign electronic filing rights to those Agents. In addition, Account Managers can submit electronic filings, but only after being assigned (or assigning oneself) as an Agent associated with one or more Forms. Public Version: November 14, 2016 Instructions for Company Registration 17 b) Who is initially appointed as Account Manager? The eRegistered person who first requests a new Company Identifier, or who transitions an existing Company Identifier to the new Company Registration system, automatically will be listed as the first Account Manager for your company. c) Can I select a Delegated Filer or a Required Filing Company to be an Account Manager? No. A Delegated Filer or a Required Filing Company cannot be selected as an Account Manager. Only eRegistered persons can be selected as account managers. However, a Required Filing Company may select individual, eRegistered people outside of your company as Account Managers. d) How do I assign Account Managers? The initial Account Manager or any additional Account Manager can appoint additional Account Managers using the “Assignment to Forms and CID Account Managers” section on the Assignment Page. An Account Manager can designate only eRegistered persons as Account Managers. Screen shots and detailed instructions on using the “Assignment to Forms and CID Account Managers” function can be found at Appendix A: How do I assign additional Account Managers? e) How do I remove Account Managers? The initial Account Manager or any additional Account Manager can remove an Account Manager using the “Assignment to Forms and CID Account Managers” section on the Assignment Page. In the “Assignment to Forms and CID Account Managers” portion of the Assignment Page, select the Account Manager that you would like to remove. Upon selection, that Account Manager will be highlighted. Click the “Remove Rep or CID” button to remove the Account Manager. NOTE: If all Account Managers or Agents are selected to be removed, an error will result. In every Company Profile, there must always be at least one Account Manager and one Agent per selected Form. Public Version: November 14, 2016 Instructions for Company Registration 18 f) How many Account Managers should my company choose? We highly recommend that you maintain multiple Account Managers at all times in the event that changes need to be made, such as adding new Agents to make filings. Also, maintaining multiple Account Managers will ensure that a company can manage its account even if a company’s Account Manager has left the company without designating a replacement Account Manager. g) Are Account Managers able to file Forms? The initial Account Manager assigned during registration of a new company or transition of an existing company automatically is assigned as an Agent, with filing rights for all Forms selected. However, subsequent Account Managers need to be added to specific Forms in order to make filings. h) Do Delegated Filers need Account Managers? Yes. Delegated Filers need at least one Account Manager to manage the Delegate Filer’s Company Registration account. i) Does Commission Staff Review the Assignment of Account Managers? No. Account Managers for CIDs and DIDs are not reviewed by Commission Staff. 3) Agents An Agent is any Delegated Filer company or eRegistered person to whom an Account Manager has assigned electronic filing rights. For each Form that your company will register, you should select the eRegistered name of every person your company wishes to designate as an Agent who may file that Form with the Commission on behalf of your company. All Agents have equal rights with regard to making an electronic filing of a Form to which they are assigned. The eRegistered person requesting a new Company Identifier will be automatically listed as the first Agent for every Form selected. a) What people or entities can be designated as an Agent? Who an Account Manager can designate as an Agent depends on whether the Public Version: November 14, 2016 Instructions for Company Registration 19 account is a Required Filing Company or a Delegated Filer. 1. Required Filing Company: An Account Manager can designate 4 eRegistered persons or Delegated Filers as Agents. There is no limit on the number of eRegistered persons or Delegated Filers an Account Manager may select as Agents for any Required Filing Company’s Form. There is also no limit to the number of Regulated Filing Companies that may select a given eRegistered person as an Agent. Each eRegistered person is responsible for maintaining the accuracy of his or her own eRegistration account. The Commission takes no responsibility for incorrect or outdated eRegistration profiles. Incorrect or outdated eRegistration information can result in an inability to access FERC Online for the purpose of making an electronic filing, not receiving Commission notifications as to the status of filings, and other consequences. 2. Delegated Filers: An Account Manager can designate only eRegistered persons as Agents. There is no limit on the number of eRegistered persons an Account Manager may select as Agents for any Delegated Filer Form. There is also no limit to the number of Required Filing Companies that may select a given Delegated Filer as an Agent. Each Delegated Filer, through its Account Managers, is responsible for maintaining the accuracy of its own Company Registration account and for managing its own list of Agents. The Commission takes no responsibility for incorrect or outdated Company Profiles. Incorrect or outdated Delegated Filer company information can result in an inability to access FERC Online for the purpose of making an electronic filing, not receiving Commission notifications as to the status of filings, and other consequences. 4 eRegistered persons: Only persons who are fully eRegistered with the Commission are available for selection by the Account Manager. The Agent’s eRegistration account must permit the eRegistered user to access FERC Online. All persons who have already completed their eRegistration do not have to reapply for a new eRegistration account to be an Agent. Instructions on how a person creates and maintains an eRegistration account are located on the Commission’s web site at www.ferc.gov. Public Version: November 14, 2016 Instructions for Company Registration 20 b) How do I assign my company’s first Agent? The initial Account Manager associated with a new Company Registration, or a transitioned Company Identifier, is automatically assigned Agent rights for all Forms selected. All additional Agents must be manually assigned. c) How do I assign Agents? An Account Manager may assign Agents using the “Assignment to Forms and CID Account Managers” section on the Assignment Page Screen shots. Detailed instructions on using the “Assignment to Forms and CID Account Managers” function can be found in Appendix A: How do I assign additional eRegistered persons as Agents? d) How do I delete Agents? An Account Manager may delete Agents using the “Assignment to Forms and CID Account Managers” section on the Assignment Page, a screen shot of which can be found in Appendix A. In the “Assignment to Forms and CID Account Managers” portion of the Assignment Page, select the Agent that you would like to remove. Upon selection, that Agent will be highlighted. Click the “Remove Rep or CID” button to remove the Agent. NOTE: If all Agents or Account Managers are selected to be removed, an error will result. In every Company Profile, there must always be at least one Agent per selected Form and one Account Manager. e) What are the filing rights of Delegated Filers assigned as Agents? Once an Account Manager for a Required Filing Company designates a Delegated Filer as an Agent for a Form, the designated Agents of the Delegated Filer assigned to that Form can make a filing on behalf of the Required Filing Company. f) Can Delegated Filers assign Agents for specific Required Filing Companies? No. A Delegated Filer only has the right to assign Agents to a specific Form the Delegated Filer is authorized to file. The Agents assigned to that Form will have the right to file the Form on behalf of any Required Filing Company that delegates the filing of that Form to the Delegated Filer. Public Version: November 14, 2016