Texas QSE To Pay $7,500 Under Settlement With PUCT Staff

Credit Suisse Energy, LLC (CSE) would pay $7,500 under a settlement with Staff of the Texas PUC to settle alleged violations of Electric Reliability Council of Texas (ERCOT) Protocols § 16.12.3, concerning market participant audits of user security administrators and digital certificates.

ERCOT Protocols § 16.12.3(1) states that "[d]uring September of each year, each Market Participant shall generate a list of its registered [User Security Administrator] and Certificate Holders. The Market Participant, through its User Security Administrator or another authorized third party, shall perform an audit by reviewing the list and noting any inconsistencies or instances of non-compliance (including, for example, any Certificate Holder that may have changed job functions and no longer requires the Digital Certificate)."

ERCOT Protocols § 16.12.3(2) states that each market participant is required to submit to ERCOT an attestation of compliance based on that audit (a Digital Certificate Audit Attestation or DCAA) by October 1 of each year. Attestations must be completed for each market participant type (e.g., counterparty, qualified scheduling entity, load serving entity, etc.).

The settlement states that CSE holds the following registration types: Counterparty and Qualified Scheduling Entity.

The settlement states that, as such, CSE was required to file two DCAAs by October 1, 2015.

The settlement states that CSE submitted its calendar year 2015 DCAAs on January 29, 2016, and, its calendar year 2016 DCAAs on March 16, 2017

The settlement states that, as such, these filings were not timely made.

The settlement states that, previously, on December 5, 2014, Commission Staff issued a warning letter to CSE regarding the lack of submission of DCAAs for calendar year 2013.

Docket 47264