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FERC/NERC Compliance Guidance Amid Potential Coronavirus Impacts

Client Alert | 1 min read | 03.19.20

The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) jointly issued compliance guidance notifying NERC-registered entities that they will consider the impact of the coronavirus outbreak as an acceptable basis for noncompliance with certain NERC Reliability Standards and related activities, as follows: 

  • Noncompliance with obtaining and maintaining personnel certification under PER-003-2, for the period March 1, 2020 through December 31, 2020, except that registered entities must notify their Regional Entities and reliability coordinators when using system operator personnel that are not NERC-certified.
  • Noncompliance with Reliability Standard requirements involving periodic actions that would have to be taken between March 1, 2020 and July 31, 2020, except that registered entities must notify their Regional Entities of any periodic actions that will be missed during this period.
  • Regional Entities will postpone on-site audits, certifications, and other on-site activities through July 31, 2020.
  • Registered entities should communicate any coronavirus-related resource impacts associated with remote activities to their Regional Entities.

Please contact us if you have any questions regarding this guidance.

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Client Alert | 4 min read | 12.23.24

Lessons for E-Commerce and Retail From the FTC and Illinois AG’s Proposed $140 Million Settlement Against Grubhub

On December 17, 2024, the Federal Trade Commission (“FTC”) and the Illinois Attorney General (“AG”) announced a $140 million settlement with Grubhub to resolve charges involving an array of allegedly unlawful and deceptive business practices. Even though the FTC’s proposed final rule on junk fees (also announced on December 17, 2024) is limited to hotels, live events, and short-term rentals, this settlement demonstrates that the FTC will use its broad enforcement powers to pursue companies imposing junk fees online, and that both federal and state consumer protection regulators will formulate 2025 enforcement priorities with junk fees and click-to-cancel in mind. Indeed, this $140 million settlement, of which Grubhub will pay $25 million based on its demonstrated inability to pay the full amount, is the first of its kind in that it is a joint action by the FTC and state regulators to pursue both junk fees and click-to-cancel violations....

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