On July 25, 2025, Chairman Mark Christie announced that the Commission's Office of Enforcement is getting a new name—the Office of Enforcement and Regulatory Accounting (OERA).1 The purpose of this name change, according to the Commission, is to "better reflect the important work" done by the entire OERA, and in particular the "regulatory accounting work" done by OERA's Division of Audits and Accounting. As Chairman Christie explains in his remarks, OERA's work "extends far beyond enforcement," and he wanted to ensure that "those doing the accounting work" are also recognized.
It is unclear whether the Commission is also signaling a change in its enforcement priorities as they related to regulatory accounting. Although the Commission's release indicates that this is a "change is in name only," Chairman Christie's decision to draw specific attention to OERA's role in ensuring "compliance . . . with FERC's regulations regarding transmission rates, including those established through formula rates[,]" may indicate substantive intent. While OERA's mission may remain unchanged on paper, OERA could nonetheless be shifting its approach and priorities concerning rate-related accounting determinations.
It may not be clear for some time whether such a shift is occurring. Much of OERA's work is non-public in nature. And when that work does become public through settlements and audit reports, those disclosures can come well after the underlying investigation or audit has commenced. Accordingly, the first indication of a shift in priorities could come in November 2025 when OERA would be expected to release its annual report on enforcement related activities.
Further lack of clarity stems from broader changes at the Commission. Chairman Christie has announced his departure from the Commission in the coming weeks, and it is not yet clear what the focus and mission of OERA will be under a Commission including current nominees Laura Swett, a former Commission enforcement staffer herself, and/or David LaCerte.
Footnote
1. https://ferc.gov/news-events/news/fercs-office-enforcement-gets-expanded-name
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