[Updated 9/5/2019]

Companies who are subject to FERC Order 714 sometimes change their names.  In our experience, this is usually the result of an acquisition or restructuring.  In any event, when this happens, the name of the licensed Company in TariffShark must be changed and TariffShark’s automated features must be considered when doing so.

Background

TariffShark has the ability to automatically insert headers and footers into your Tariff content.  This feature allows you to focus on the content your tariffs while providing contextual tariff information (Company name, Tariff name, section name, sheet number, effective date, etc.) to your readers.  TariffShark does this by placing actual Tariff metadata into the headers and footers of your tariff content.  For example, if you configured TariffShark to insert the effective date in the footer of your tariff provisions and you were to change the effective date of a tariff provision, TariffShark would automatically update the provision’s PDF(s) to reflect the new effective date.

TariffShark provides this ability flexibly by allowing you to define different headers and footers for different tariff provisions.  For example, you might want your tariff’s title page to not have a header or footer, your tariff’s rates to be formatted with landscape-style headers and footers, and the rest of your tariff’s content to have portrait-style headers and footers.  So, even within a single Tariff, different Header and Footer combinations could be present.

Some companies, especially those in FERC’s NGA Gas program and electric industry companies with Open Access Transmission Tariffs, use TariffShark to publish their effective tariff provisions.  Publishing is a process whereby the various tariff provisions that are in effect at a point in time are brought together into a single document.  When publishing, TariffShark can generate and include a table of contents at the beginning of the published document and also an index at the end of the published document.  These automatically generated elements include the name of the Company at the top of each page.

Finally, TariffShark is licensed by Company.  The names of the Companies licensed to use TariffShark are listed in a license file on the TariffShark Application Server.  When updating the name of a licensed Company, it may be necessary to update the license file.

Changing Company Name in TariffShark

There are three alternative methods to effect a Company name change in TariffShark.

Method #1: New Company

The first method involves cancelling all Tariffs under the old Company name and submitting baseline Tariffs under the new Company name.  The automated processes described under the “Background” heading above are unaffected by this approach, however, it requires an updated TariffShark license file that adds a license for the Company under its new name.  Also, because the FERC Company Id doesn’t change, when creating the new Company in TariffShark, it is necessary to set the “Next FERC Filing Id”, the “Next FERC Tariff Record Id”, and the “Next FERC Tariff Database Id” to values that are higher than the values shown for the same fields in the current Company.

This method is the most natural fit from a software perspective, but may inflict the most regulatory pain as it requires entire Tariffs to be refiled.  In addition, FERC Staff does not recommend cancelling Tariffs just because of a Company name change.

Method #2: Don’t Update the Company Name At All

The second method is a “trick” of sorts as the Company name isn’t updated at all.  If the automated TariffShark features described under the “Background” heading above aren’t used for the Company, then there is no compelling reason to update the Company name in TariffShark.

If the Company name appears in Header/Footer Templates, Method #2 can still be used.  Create separate Templates for the old Company name and the new Company name by following these steps:

(2a) Make copies of all Header Templates or Footer Templates where the [Company Name] symbol is used to insert the Company name.

(2b) In the copies, replace the [Company Name] symbol with the new name of the Company.

(2c) Next, make new Document Layouts as copies of existing Document Layouts that use the new Header/Footer Templates created in steps (2a) and (2b).

(2d) At the Tariff Database level, use the “Replace Document Layouts” command to select the current Document Layouts, and specify that they be replaced with the new Document Layouts created in step (2c).  From this point forward, all new Tariff Record Versions will use the new Document Layouts and, therefore, the new Company name will appear in the Headers/Footers.

If the publishing features to automatically generate Tables of Contents and/or Indices are used for the Company, then Method #3 is likely the best fit.

Method #3: Update Company Name

The third and final method requires that the Company name is updated in TariffShark.  If the automated TariffShark features described under the “Background” heading above are used for the Company, then the best course of action is to update the name of the Company in TariffShark.

If the Company name appears in Header/Footer Templates, then separate Templates are needed for the old Company name and the new one.  Create these Templates by following these steps:

(3a) Make copies of all Header Templates or Footer Templates where the [Company Name] symbol is used to insert the Company name.

(3b) In the original Templates (not the copies), replace the [Company Name] symbol with the old name of the Company.  When the Header/Footer Templates are updated in TariffShark, all Tariff Record Versions that use them will be reprocessed.  However, because the [Company Name] symbol was replaced with the current Company name, the resulting PDFs will appear unchanged.

(3c) Next, make new Document Layouts to parallel the existing Document Layouts, only use the copied Header/Footer Templates created in step (3a).

(3d) Update the Company name in TariffShark.  In order to complete this task, you will need an updated TariffShark license file and a SQL script.  Contact TariffShark Support to complete this step.

(3e) At the Tariff Database level, use the “Replace Document Layouts” command to select the current Document Layouts, and specify that they be replaced with the new Document Layout(s) created in step (3c).  From this point forward, all new Tariff Record Versions will use Document Layouts that leverage the original Header/Footer Templates.  Therefore, the new Company name will appear in the Headers/Footers.

Summary

Depending on how you use TariffShark, choose the method for changing Company name that’s the best fit.

	Updated License File Needed	Document Layout and Header/Footer Template Work Required	Auto-Generated Publishing Content Affected	Tariffs Must Be Cancelled and Re-Baselined	SQL Script Required to Update Company Name
Method #1	✔			✔
Method #2		✔	✔
Method #3	✔	✔	✔		✔

If you have questions or would like to discuss these options in greater detail, we’d love to hear from you.  Comment below or contact TariffShark Support.