Archived Webinar

Evaluating Your Compliance Program Under FERC's Penalty Guidelines

Overview

  • Event Held On: 3/8/2012

Full Event Description

The new “Penalty Guidelines,” issued by Federal Energy Regulatory Commission (FERC), contain a new and explicit list of components for a “successful compliance program.” If your company comes under review – an event that borders on certainty if you are a large energy company - you could be given a compliance score that has serious implications for your bottom line.

Join Todd Mullins, Partner at McGuireWoods, Former FERC official and key contributor to the development of FERC’s “Penalty Guidelines” as he reviews how the Penalty Guidelines work and how the compliance score is established and demonstrates the powerful impact of a good compliance score through several case scenarios.

In this webinar, we will:

  • Identify specific economic benefits of a compliance program
  • Review a best-practice compliance program check list to stay within FERC guidelines and raise your score
  • Address how to handle the more tricky elements of compliance
  • Provide useful talking points to use when talking with senior leadership about FERC compliance
  • Teach you how to reduce potential costs and complications of regulatory enforcement through specific tools and metrics in your compliance program

Join us on March 8th as we learn how the Compliance Score works, what it means, and how increase your score – saving yourself and your company hassle, stress and potentially large legal fees.

Speaker Biographies

Todd  Mullins, McGuireWoods LLP

Todd Mullins
Partner, McGuireWoods LLP

Mr. Mullins is a partner with McGuireWoods LLP and serves as chair of the Energy Enforcement practice group. He represents energy clients with enforcement and compliance matters involving the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the North American Electric Reliability Corporation (NERC) and other regulators, as well as in related private litigation. Mr. Mullins, a trial lawyer with over 20 years of experience representing energy companies, from 2006-2010 was a lead enforcement official at FERC.

His experience there included leading cases and policy development for FERC under the Energy Policy Act of 2005 (EPAct 2005), including market manipulation cases (e.g., Amaranth/Hunter, the first FERC market manipulation case), electric reliability matters (e.g., Florida Blackout, the first FERC electric reliability case, Office of Enforcement lead on Order No. 693 that approved the Reliability Standards), and general enforcement program matters (policy statement development, development of practices, prosecutorial discretion standards). Just before his departure from FERC, he was instrumental in developing FERC's "Penalty Guidelines" that will have a significant impact on compliance programs and enforcement matters.

These all have significance under the new "$1 million per violation, per day" civil penalty authority implemented under EPAct 2005. Since arriving at McGuireWoods he has assisted over twenty clients with various matters involving enforcement and compliance in the energy space, and regularly conducts compliance training and assists with compliance program design.

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