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FERC Standards of Conduct Training - CenterPoint Energy

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Contemporaneous Disclosure<br />

Further, in order to avoid any appearance <strong>of</strong> undue preference,<br />

any disclosure <strong>of</strong> non-public transmission function or customer<br />

information to a customer or potential customer, even if that entity<br />

is not an Affiliate with MFEs, should be reported to the Chief<br />

Compliance Officer (<strong>FERC</strong>) so a determination can be made<br />

whether a self-report to <strong>FERC</strong> <strong>of</strong> the disclosure is required.<br />

Posting improperly disclosed information on the applicable Internet<br />

website does not relieve EGT or MRT from possible liability for<br />

violating the <strong>Standards</strong> <strong>of</strong> <strong>Conduct</strong>, and EGT or MRT may still be<br />

subject to penalties (up to $1 million per day per violation) for the<br />

disclosure.<br />

However, promptly posting the disclosed information does prevent<br />

any penalties from continuing to accrue for each day the<br />

information was available to the MFE but not also available to the<br />

public, and may reduce the severity <strong>of</strong> any penalty.<br />

35<br />

For Internal Use Only

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