For our friends with interlocking positions at multiple FERC-jurisdictional entities, your annual reports are due Wednesday, April 30. For background, individuals cannot hold multiple management positions, including officer and director positions, across multiple entities with FERC Authority without prior authorization. After getting authorization, these officers and directors must file Form 561 annual reports thereafter. Form 561 details electric public utility officer and board of director positions that officers and directors held within and outside their affiliated public utility at any point during the preceding year. The reports are based on last year’s information.

Here are Our Top 6 FAQs from FERC on Form 561:

1. What is the filing deadline for the Form No. 561?

• Filings are due on or prior to April 30th for the previous calendar year.

2. Why is the Form No. 561 data collected?

• The Commission uses this data collection to determine whether public or private interests will be adversely affected by the holding of these positions. The data is collected to monitor what positions electric industry officers and directors hold in organizations that do business with each other. This information allows the Commission to monitor and assess the possibility of an officer or director having a conflict of interest which harms public or private interests.

3. Who is responsible for filing Form No. 561?

• Public utility officers/directors who held interlocked positions during any part of the previous calendar year are responsible for filing Form No. 561.

4. If an officer or director resigned during the year does he or she still have to file a Form No. 561?

• Yes, a Form No. 561 is required of the officer or director who held the interlocked position during any part of the previous calendar year even if he/she did not hold it at the close of the year.

5. If I have interlocking positions and the utility for which I am an officer or director has market-based rate sales authority, do I still have to file a Form No. 561?

• Yes. You are still required under 18 CFR 46.4 to file Form No. 561.

6. If an officer or director resigned during the year, does he/she need to file a Form No. 561?

• Yes, a Form No. 561 is required of the officer or director who holds an interlocking position during any part of the previous calendar year even if he/she did not hold it at the close of the year. If a utility representative normally files on behalf of the retired officer/director and the whereabouts of the retiree have become unknown, the representative should prepare an unsigned form and report the appropriate reason. Additionally, the representative may need to submit a Notice-of-Change.