XBRL US submitted a letter to the Federal Energy Regulatory Commission (FERC) in response to their request for comment on Data Collection for Analytics and Surveillance and Market-Based Rate Purposes. The focus of the XBRL US letter was on the section in the proposal that market-based rate sellers provide utility identifiers for certain upstream affiliates whose securities were acquired. The Commission proposed that sellers be allowed to select one of three identifier types for the reportable entity:
- Company Identifier (CID) which would be required if it is available;
- Legal Entity Identifier (LEI) which would be required if it is available, and if the CID is not available; or
- FERC generated ID (GID), if the CID and the LEI are not available.
The XBRL US letter supported the requirement that an identifier be reported, but strongly encouraged the Commission to require only one identifier type, and that the LEI be the identifier for all reporting entities. Furthermore, the letter encouraged the FERC to require that those entities that do not have an LEI, obtain one.
Read the XBRL US letter: XBRL US Response FERC Docket No. RM16-17-000