The Federal Energy Regulatory Commission (FERC) started accepting operational and financial filings in the XBRL format from the energy utilities it oversees starting from the third quarter of 2021. XBRL, which stands for eXtensible Business Reporting Language, is an open data format that is preferred by regulatory authorities around the world for collecting information from the entities they regulate.
The XBRL format turns data interactive and computer-readable, facilitating complex data analysis, comparison of trends across entities and industry sectors, and judging the viability of financial and operational projections.
FERC, by adopting XBRL, has moved away from the now obsolete Visual FoxPro-based filing system which Microsoft has stopped supporting. While XBRL brings the aforementioned benefits, energy companies across the US still have a number of questions about the format, some of which we are trying to deal with in this blog.
Here are 10 FAQs
Q1. Do the operating hours of the Federal Energy Regulatory Commission (FERC) affect filings?
Monday through Friday, excluding public holidays, FERC is open from 8.00 am to 5.00 pm Eastern Time (GMT -4). Submissions to FERC outside of these hours may be marked as “Processing – Rendering” and will be considered during business hours.
Q2. ‘Consecutive Three-day Peak Deliveries’ (Form 2, Page 518) – How many dates should we enter for this line item?
You will only need to provide one date, which will be the first of the three peak days. FERC may release a revised taxonomy following the current Q4 filings, allowing filers to enter several dates and stating that if any further information is needed with respect to the date, filers must include it as a footnote.
Q3. On page 101 of Form 1, there is a field for ‘Date of Incorporation.’ What about the ‘Date of Re-Incorporation’?
There is currently no way to enter the ‘Date of Re-Incorporation.’ You can add a footnote to the Date of Incorporation if you want to indicate the Date of Re-incorporation.
Q4. What should you put in the ‘State of Incorporation’ box on Page 102 of Form 2 if it’s a foreign address?
Filers must enter any US state code and then include a footnote with the foreign address to meet the validation requirement. FERC may elect to amend the taxonomy in the future to enable foreign addresses in this area.
Q5. How can I verify the status of my submissions on the FERC portal?
Your filings will be accessible through FERC eForms. You can start with a Test file and then move to a Live file. You’ll be able to access all your Test files once you log in to the portal. If the test filing status is ‘Tested-Valid,’ you can open the HTML file to cross-check if all your values are shown. You can be sure to do a Live filing once you’ve finished checking. If you cannot log in to the aforementioned portal, then your live filing can be viewed under the Public Submission history. Its status should be shown as ‘Accepted’. If your Test or Live filing fails, you will be able to discover the cause for failure by clicking on ‘Validation Message.’
Q6. Can I use FERC’s migrated data to roll forward filings?
Yes, values from the prior year/quarter can be carried forward. Check with your service provider. They should have provided you with this option.
Q7. How do I know if the form type for submission has been allocated to me?
After logging in to FERC eForms, look under ‘New Filing’ to see if the form type you’re planning to file is listed.
To do the aforementioned, you must first be allocated the appropriate form type in the FERC Online – Home Page under Company Registration.
Q8. How do you add additional recipients to FERC’s email notifications about live and test filings?
Go to FERC Online – eFiling and follow the steps outlined in the screenshot below.
Q9. What is the significance of line items 5.1, 5.2, 14.1, 14.2, and so on in the rendered output?
These line items are created because they are inserted in the sub-schedules of the main schedules. These can be found on pages such as 118 – Retained earnings and 120 – Statement of cash flow. FERC may have included these line items to avoid footnotes under each item explaining how an amount has come about and to account for the explanations separately.
As a result, the sum of the child elements from the sub schedule will be displayed against lines 5 or 14, and 5.1, 5.2, and 5.3 are the child components coming in from the proper sub schedules, as shown in the rendered output.
Q10. How can I attach a CPA certificate (if applicable) to my filing? Where do I put System Maps?
The procedure for attaching a CPA certificate has not changed. Filers will be expected to attach this to their files in the FERC Online – eFiling the way they used to do it before. Another alternative is to attach it after a submission on the FERC eForms portal. System maps must be attached directly to Form 2 schedule 522.1.
If you have any questions about your FERC filings, please write to me at firstname.lastname@example.org. I will do my best to assist you or direct you to the right channel for assistance.