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Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Mark - ECT Legal Taylor X-To: Alan B Aronowitz X-cc: X-bcc: X-Folder: \Mark_Taylor _Dec_2000\Notes Folders\Sent X-Origin: Taylor-M X-FileName: mtaylor.nsf Alan: Are you still the code of conduct person? If not, let me know & I'll keep looking. Mark ---------------------- Forwarded by Mark - ECT Legal Taylor/HOU/ECT on 12/14/98 04:53 PM --------------------------- Mary Solmonson 12/14/98 10:38 AM To: Christian Yoder/HOU/ECT@ECT, Vicki Sharp/HOU/EES@EES, Sheila Tweed/HOU/ECT@ECT, Jeffrey T Hodge/HOU/ECT@ECT, Mark - ECT Legal Taylor/HOU/ECT@ECT cc: Debbie R Brackett/HOU/ECT@ECT, Sheila Glover/HOU/ECT@ECT Subject: Enron-Wide Global Counterparty Implementation - Code of Conduct Guidance/Approval Requested We have been asked to implement the Global Counterparty (GCP) system at Portland General and EES to support Global Credit Aggregation with our major trading partners. This information includes Counterparty Name, various Address data such as documentation (confirmation), headquarters, and settlement (including wire bank, ABA, and routing), and various contact names and phone numbers such as trader, settlements, etc. For Global Credit Aggregation to be supported most efficiently, all Enron companies must utilize a common identifier for the counterparty on a trade, i.e., Southern Energy Marketing for Portland = Southern Energy Marketing for ECT = Southern Energy Marketing for EES = Southern Energy Marketing for EPMI. Global Credit must 'see' exposure from each affiliate for a counterparty as the same party to aggregate to a corporate level. For Portland General, the list of trading partners are mostly parties we already have in the GCP database. However, there will be some counterparties that are specific to Portland General (the same could also be true about EES). For that reason, I would like to train specific individuals at each company to perform the GCP administration/maintenance for their counterparties much like we handle the ECT London and Calgary operations. What we will have is a system shared as depicted below : There would be select individuals at each company to maintain their counterparty information via Terminal Server in a common database maintained here in Houston by ECT IT. This type of access would give these individuals access to Counterparty data for all companies regardless of their own company affiliation. Each company/business unit will have an extract or view from the main database of only their counterparties to support their trading and downstream systems versus those systems being integrated directly with the main database containing all information. What I need to know is whether any of you see a problem with this 'sharing' of technology and data between ECT and PGE or EES and the intended implementation. Based on Bill Dassenko's understanding of the FERC Code of Conduct, we think this proposal is within the guidelines. Please provide any comments or your acceptance of this proposal by Monday, December 21st. Thank you. ---------------------- Forwarded by Mary Solmonson/HOU/ECT on 12/14/98 08:43 AM --------------------------- Debbie R Brackett 12/11/98 04:48 PM To: Mary Solmonson/HOU/ECT@ECT cc: Subject: Counter Party Name List Mary, This is the list we talked about. Reviewing it briefly, I only see a few that we don't already have in GCP. In discussing this with Bill (Dassenko), he sees no reason under the FERC code of conduct that we cannot see ( or share) public information about shared counterparties such as would be populated in GCP. He is prohibited from sharing specific deal info or exposures, neither of which would be an issue in GCP. Hope this helps...I'll be back in on Tuesday and we can talk more if you need to. Debbie ---------------------- Forwarded by Debbie R Brackett/HOU/ECT on 12/11/98 04:41 PM --------------------------- From: HQ3.EM5:Bill Dassenko AT PORTLAND_PO@CCMAIL on 12/11/98 03:58 PM To: Debbie R Brackett@ECT cc: Subject: Counter Party Name List Date: 12/11/1998 03:58 pm (Friday) From: Bill Dassenko To: Brackett, Debbie R Subject: Counter Party Name List Debbie, Attached is a file containing PGE's list of counterparties. There are a few financial counterparties which I have not yet included on this list. All names on the list are wholesale counterparties with which PGE trades power or gas or are wholesale customers. There are no retail customers on this list. In general, under the FERC "Code of Conduct" rules established for working with affiliated companies, the unregulated entity (ECT, EPMI) can tell all to the regulated entity, but the regulated entity (PGE) can share in only the most general of terms. Further, PGE conversations can not convey any information which is otherwise not public about PGE's markets or customers. Although the question is a good, I believe I have more to worry about when talking to you than what you do when talking to me. Given that I have included as complete a list as I have. Christian Yoder is the ECT lawyer who is tasked with code of conduct issues for ECT. His phone number is 503-464-7845. - List.xls
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