Federal Register - August 26, 2021

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Fuente: Federal Register

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Federal Register / Vol. 86, No. 163 / Thursday, August 26, 2021 / Rules and Regulations
12. GLEIF and XBRL support adding the proposed new data fields to the relational database and also support usage of the Legal Entity Identifier LEI
in the Utility_ID_Type_CD attribute proposed field 11 in the entities_
to_entities table.22 However, both GLEIF and XBRL suggest that the Commission incorporate the LEI more broadly by requiring the reporting of an LEI in all cases.23 GLEIF argues that partial inclusion of the LEI results in partial coverage, which limits the potential benefits of using the LEI.24
GLEIF further argues that consistent use of the LEI among U.S. federal agencies could greatly enhance information sharing across different government entities.25 XBRL urges all U.S. regulators to adopt the LEI as a replacement for the industry-specific identifiers used today and adds that LEIs provide clarity regarding organizational provenance, and help businesses understand the origins of clients, contractors, and suppliers.26
13. EEI and EPSA believe there is little to no value in reporting ultimate upstream affiliates that are institutional investors to the relational database and express concern that adopting the proposed changes will result in another delay in implementation. As a result, EEI and EPSA urge the Commission not to move forward with the proposed changes.27 If the Commission moves forward with its proposal to collect information about institutional investor ultimate upstream affiliates in the relational database, EEI and EPSA
suggest several modifications and clarifications, which they believe are needed to make the proposed changes less cumbersome, more understandable, and easier to implement.28
14. First, EEI and EPSA explain that use of the term utility in the proposed new data fields Utility_ID_Type_CD and Utility_ID to identify the entity whose securities were acquired by a Sellers ultimate upstream affiliates pursuant to a section 203a2 blanket authorization may confuse the industry because, in most cases, such an entity is not a public utility, as defined by the FPA, but is instead a public utility holding company.29
15. Second, EEI and EPSA express concern about the workability of the Commissions proposal regarding the 22 See
GLEIF Comments at 1; XBRL Comments at
jbell on DSKJLSW7X2PROD with RULES

1.
23 Id.
24 GLEIF

technical implementation and seek clarification on which attributes will be used to generate a Sellers asset appendix.30 Specifically, in the case that only the Utility_ID attribute will be used to link affiliated Sellers for purposes of generating the asset appendix, EEI and EPSA express concern that the nullable Utility_ID attribute will be blank for thousands of Sellers because they do not have ultimate upstream affiliates that acquired the securities of the Seller through a section 203a2 blanket authorization. On the other hand, in the case that both the Utility_ID attribute and the Reportable_Entity_ID attribute will be used to link affiliated Sellers for purposes of generating the asset appendix, EEI and EPSA argue that this would be far more complex than always using one attribute i.e. the Reportable_
Entity_ID. EEI and EPSA argue that an additional benefit of always using the Reportable_Entity_ID attribute to link affiliated Sellers is that the Reportable_
Entity_ID is likely to remain fixed for many years for most Sellers, whereas the existence of an institutional investor ultimate upstream affiliate may vary from quarter to quarter.31 EEI and EPSA
suggest that, should the Commission decide to move forward with its proposal, the concept of Reportable Entity should always be the entity that is used to compile the asset appendix and suggest that the Commission rename this field to be Asset_Appendix_
Reportable_Entity.32
16. Third, EEI and EPSA seek clarification on whether the data fields relationship_start_date and relationship_end_date now refer to the relationship between a Seller and the Reportable Entity or to the relationship between a Seller and the utility, in the event that both fields are populated. EEI
and EPSA suggest that two additional fields be added so that the relational database captures the start and end date of both relationships, when applicable.33
17. Finally, EEI and EPSA express concern that the Commission has not allowed adequate time for its proposed changes to be incorporated into software that Sellers may be relying on to create the XMLs for their database submissions, and request that any order in this docket include a step-by-step example to ensure that Sellers software developers understand the correct approach to updating records.34
30 Id.

at 5.
31 Id. at 56.
32 Id. at 89.
33 Id. at 6, 9.
34 Id. at 8.

26 XBRL

Comments at 2.
and EPSA Comments at 10.
28 Id. at 3.
29 Id. at 4.
27 EEI

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18. We adopt the revisions to the MBR
Data Dictionary, as proposed in the March Notice. In doing so, we provide additional clarification to address concerns raised by commenters. We note that all commenters agree that it is important to distinguish upstream affiliates that have control over Sellers, ultimate upstream affiliates that have received section 203a2 blanket authorizations, and the upstream affiliates or Sellers whose securities were acquired pursuant to that blanket authorization. We find that the revisions, with the clarifications discussed below, strike the appropriate balance between ensuring the accuracy of auto-generated asset appendices and minimizing the burden on Sellers.
Below, we respond to commenters specific suggestions and concerns.
19. We decline to adopt the proposal that the Commission incorporate LEI
more broadly by requiring the reporting of an entitys LEI broadly across the Commissions work. We appreciate XBRLs and GLEIFs emphasis on consistency and transparency throughout the Commissions information collection efforts. However, we find that such a proposal is beyond the scope of this proceeding, which more narrowly addresses the accurate identification and reporting of ultimate upstream affiliates in the relational database.
20. As to the argument that there is little to no value in reporting ultimate upstream affiliates where those entities have acquired the securities of the reporting Seller, or its upstream affiliate, pursuant to a section 203a2 blanket authorization order, we note that the Commission has repeatedly emphasized the importance of both identifying and tracking these ultimate upstream affiliates in the relational database.35 We believe that continuing to require Sellers to report all of their ultimate upstream affiliates and the information discussed herein will preserve the accuracy and integrity of the relational database, as contemplated in Order Nos.
860 and 860A. These additional data fields will account for instances where certain ultimate upstream affiliates lack control over those Sellers, or their upstream affiliates, whose securities are acquired pursuant to a section 203a2
blanket authorization.36 Thus, these 35 See, e.g., NextEra, 174 FERC 61,213 at P 56;
Order No. 860A, 170 FERC 61,129 at P 11.
36 Notably, there is no dispute that entities that own greater than 10% of the voting securities of a market-based rate seller pursuant to a section 203a2 blanket authorization are affiliated with that seller.

Comments at 2.

25 Id.

C. Commission Determination
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Federal Register - August 26, 2021

TítuloFederal Register

PaísEstados Unidos de América

Fecha26/08/2021

Nro. de páginas481

Nro. de ediciones7796

Primera edición14/03/1936

Ultima edición16/06/2026

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