FRMSTF Recommendations Dashboard

The Financial Risk Mitigation Senior Task Force (FRMSTF) dashboard is a webpage designed to assist stakeholders in correlating the recommendations included in the Report of the Independent Consultants on the GreenHat Default against the activities and progress of the workstreams. Information will be updated regularly coinciding with the FRMSTF publication schedule and work plan.

Recommendations

A Advance Credit/Collateral Best Practices into the Tariff
B Clarify the Role of PJM as Manager of Risk in Financial Markets
C Build a Customer Awareness Beyond Market Procedures & Rules
D Implement Technical Practices for Participant Risk Management
F Increase the Frequency of Long-Term Auctions

A) Advance Credit/Collateral Best Practices into the Tariff
1. The PJM Credit Policy Failed to Address Critical Risks
ID	Recommended Actions	Work Stream	Progress	Completed
A1	Use the mark to auction values established in the more frequent auctions (see recommendation F) as the basis for “variation margin,” 13 charging as a current debt the value erosion between the purchase price and the current market value as determined by the latest auction.	Credit and Risk Management/Models	A discussion paper examining variation margining and how it could work for the FTR market, as well as other settlement options in the period following an FTR auction was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Market Reform Project Discussion Paper – Variation Margin and Post Auction Settlement The FTR Product Range and Auction Process package was endorsed at the 12.19.19 MRC. Final endorsement was received at the 1.16.2020 meeting of the MC. On February 14, 2020, in Docket No. ER20-1009-000, PJM submitted proposed revisions to the PJM Tariff. PJM received FERC approval on this item with an effective date of April 15, 2020.	Complete
A1.1	This will help to capture the credit risk for all FTRs, not just near term FTRs, and reduce the current volatility of margining due to infrequent auctions.	Credit and Risk Management/Models	A discussion paper providing an overview of variation margining and post auction settlement was presented at the A report on Position and Concentration Limit options was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Market Reform Project Discussion Paper – Variation Margin and Post Auction Settlement The FTR Product Range and Auction Process package was endorsed at the 12.19.19 MRC. Final endorsement was received at the 1.16.2020 meeting of the MC. On February 14, 2020, in Docket No. ER20-1009-000, PJM submitted proposed revisions to the PJM Tariff. PJM received FERC approval on this item with an effective date of April 15, 2020.	Complete
A2	Retain the current 10¢/MWh minimum charge, in addition to purchase price, as a form of “original margin” 15 until such time as more precise measurements become available to determine original margin.	Credit and Risk Management/Models	A report addressing the results of a risk model quantitative analysis was presented at the 9.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A report addressing Part 2 of the results of a risk model quantitative analysis pertaining to Monte Carlo simulations was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF).
A3	Eliminate the FTR undiversified adder because it is uncorrelated to market risk.	Credit and Risk Management/Models
A4	Define a default as any participant that is unable to meet a monthly variation margin call within two business days.	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination.
A4.1	Require that the default be declared promptly and without negotiation.	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed

B) Clarify the Role of PJM as Manager of Risk in Financial Markets
2. PJM Did Not Take Robust Policy Actions Following Precedent Experience 5. PJM Surrendered an Early Opportunity to Stop or Restrain GreenHat
ID	Recommended Actions	Work Stream	Progress	Completed
B1	PJM should revisit its existing stakeholder process to better facilitate member-to-PJM directions on advances in financial market policies and procedures.	Stakeholder Process Changes/Governance	Please see B1.1-1.3 for status updates	Completed
B1.1	Seek an equitable and efficient process centered on the relevant expertise that each PJM member may bring.	Stakeholder Process Changes/Governance	A discussion paper to explore options to address recommendations B1.1 – B1.3 was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). This discussion paper was entitled: Enduring Governance of PJM’s Financial Market An initial proposal by PJM was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated version of PJM’s initial proposal was presented at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF) which included the addition of subcomponents in the solutions matrix. An updated version of PJM’s initial proposal on Stakeholder Process and Governance including stakeholder alternatives was presented at the 11.21.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An update regarding the Stakeholder Governance proposal was presented at the 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). All proposed solutions have been withdrawn and therefore no vote will be required. The recommendation is to retain status quo for this work stream. Stakeholders and PJM were in mutual agreement to retain status quo for this work stream.	Completed
B1.2	Financial market member committees: voting attendees must be qualified member personnel, such as credit professionals, traders, or finance professionals, as appropriate for the committee duties.	Stakeholder Process Changes/Governance	A discussion paper to explore options to address recommendations B1.1 – B1.3 was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). This discussion paper was entitled: Enduring Governance of PJM’s Financial Market An initial proposal by PJM was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated version of PJM’s initial proposal was presented at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF) which included the addition of subcomponents in the solutions matrix. An updated version of PJM’s initial proposal on Stakeholder Process and Governance including stakeholder alternatives was presented at the 11.21.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An update regarding the Stakeholder Governance proposal was presented at the 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). All proposed solutions have been withdrawn and therefore no vote will be required. The recommendation is to retain status quo for this work stream. Stakeholders and PJM were in mutual agreement to retain status quo for this work stream.	Completed
B1.3	The number of committees involved in rule setting for financial markets should be strictly minimized to streamline decision making and assure clear accountability.	Stakeholder Process Changes/Governance	A discussion paper to explore options to address recommendations B1.1 – B1.3 was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). This discussion paper was entitled: Enduring Governance of PJM’s Financial Market An initial proposal by PJM was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated version of PJM’s initial proposal was presented at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF) which included the addition of subcomponents in the solutions matrix. An updated version of PJM’s initial proposal on Stakeholder Process and Governance including stakeholder alternatives was presented at the 11.21.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An update regarding the Stakeholder Governance proposal was presented at the 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). All proposed solutions have been withdrawn and therefore no vote will be required. The recommendation is to retain status quo for this work stream. Stakeholders and PJM were in mutual agreement to retain status quo for this work stream.	Completed
B2	PJM should work with FERC to establish appropriate flexibility in policies and rulemaking concerning financial markets. Following are a few specifics we see at this time:	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination.	Completed
B2.1	Amend tariff rules to make a parallel rule for FTR contracts, and other markets, to the provisions in Attachment Q for Peak Market Activity Transactions.	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
B2.2	Amend rules to include within the definition of Material Adverse Change in Attachment Q an inability to meet any PJM margin call within two business days.	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
B2.3	Provide rules that give PJM discretion to deal with unanticipated market emergency events.	Credit and Risk Management/Models	A discussion paper addressing default and termination events was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Events of Default and Market Participation Termination. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
B3	As benchmark for progress with B1) and B2) - Examine the specifics and the cost/benefits of outsourcing to a credible outside provider the administration of all or part of the FTR market.	Credit and Risk Management/Models	A position paper to address recommendation B3 was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). This position paper was entitled: FTR Default Allocation and Central Counter-Party An FTR Clearing Proposal was presented by Nodal Exchange at the 9.24.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A discussion paper addressing external clearing and an analysis of the Nodal Exchange proposal was presented at the 9.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: External Clearing for the PJM FTR Market. A presentation on FTR External Counterparty Clearing was discussed at the 3.24.2021 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A presentation on Governance of Nodal Clear and the Costs for FTR Clearing was presented by Nodal Exchange at the 6.2.2021 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A presentation on PJM Costs for FTR Clearing was presented at the 6.2.2021 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A white paper was shared and discussed on PJM’s analysis and recommendation regarding External Clearing at the 8.4.2021 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF).

C) Build a Customer Awareness Beyond Market Procedures & Rules
3. PJM Failed to Perform Adequate "Know Your Customer" Procedures
ID	Recommended Actions	Work Stream	Progress	Completed
C1	Perform outsourced background checks for any member applicant, and should the applicant not be a public company, for the three most senior officers.	Membership Qualifications/Market Participation	A position paper on PJM’s recommended changes for criteria associated with new and ongoing membership requirements was presented at the at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Due Diligence Criteria and Assessment Process A presentation reviewing concepts associated with implementing best practices related to the credit, collateral management, and know your customer were presented at the 10.18.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The presentation was entitled: Credit Industry Standards and Best Practices An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting.The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
C2	Perform due diligence by confirming that an applicant for membership actually employs the systems and processes for risk management as represented.	Membership Qualifications/Market Participation	A position paper on PJM’s recommended changes for criteria associated with new and ongoing membership requirements was presented at the at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Due Diligence Criteria and Assessment Process A presentation reviewing concepts associated with implementing best practices related to the credit, collateral management, and know your customer were presented at the 10.18.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The presentation was entitled: Credit Industry Standards and Best Practices An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
C3	Provide explicit power for the rejection of a membership application should standards of good background and regulatory history not be met.	Membership Qualifications/Market Participation	A position paper on PJM’s recommended changes on the authority to deny trading rights was presented at the at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: PJM Authorities and Discretion to Deny or Revoke Trading Rights A presentation reviewing concepts associated with implementing best practices related to the credit, collateral management, and know your customer were presented at the 10.18.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The presentation was entitled: Credit Industry Standards and Best Practices An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
C3.1	Create an internal appeal mechanism in order to address any claims of any undue discrimination swiftly without unnecessarily involving FERC.	Membership Qualifications/Market Participation	A position paper on PJM’s recommended changes on the authority to deny trading rights was presented at the at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: PJM Authorities and Discretion to Deny or Revoke Trading Rights A presentation reviewing concepts associated with implementing best practices related to the credit, collateral management, and know your customer were presented at the 10.18.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The presentation was entitled: Credit Industry Standards and Best Practices An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC. Please note status quo was retained for this item.	Completed
C4	Update the financial qualifications of participant companies at least annually and clarify PJM’s rights to act on a member’s failure to meet those requirements.	Membership Qualifications/Market Participation	A discussion paper addressing financial criteria for market participation was presented at the 9.5.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Establishing Financial Criteria Assessment and Credit Policy Enhancements for FTR Market Participation. A presentation reviewing concepts associated with implementing best practices related to the credit, collateral management, and know your customer were presented at the 10.18.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The presentation was entitled: Credit Industry Standards and Best Practices An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed

D) Implement Technical Practices for Participant Risk Management
4. PJM Management Failed to Establish Robust Participant Risk Management Tools and Procedures
ID	Recommended Actions	Work Stream	Progress	Completed
D1	Clarify with the IMM any PJM expectations regarding participant risk management of (some) participant behaviors and reporting such with PJM.	Market Rules/FTR Product Range		Complete
D2	Establish position limits for FTRs:	Credit and Risk Management/Models	A report that examined limits on position, other forms of concentration limit, and the related topic of liquidity risk was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Market Reform Project Discussion Paper – Position Limits and Liquidity Risk An examination of the pros and cons of potential approaches for calculating initial margins for participant FTR portfolios, with a recommended options for moving forward with the development of proof-of-concept models and associated back-testing was presented at the 7.17.2019 meeting of the FRMSTF. The report was entitled: Initial Margin Methodology Desktop Review. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Completed
D2.1	Based upon company capitalization.	Credit and Risk Management/Models	A report that examined limits on position, other forms of concentration limit, and the related topic of liquidity risk was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Market Reform Project Discussion Paper – Position Limits and Liquidity Risk An examination of the pros and cons of potential approaches for calculating initial margins for participant FTR portfolios, with a recommended options for moving forward with the development of proof-of-concept models and associated back-testing was presented at the 7.17.2019 meeting of the FRMSTF. The report was entitled: Initial Margin Methodology Desktop Review. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Complete
D2.2	Based upon position tenor (tighter limits towards the back).	Credit and Risk Management/Models	A report that examined limits on position, other forms of concentration limit, and the related topic of liquidity risk was presented at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Market Reform Project Discussion Paper – Position Limits and Liquidity Risk An examination of the pros and cons of potential approaches for calculating initial margins for participant FTR portfolios, with a recommended options for moving forward with the development of proof-of-concept models and associated back-testing was presented at the 7.17.2019 meeting of the FRMSTF. The report was entitled: Initial Margin Methodology Desktop Review. An initial proposal by PJM on recommended changes to the Market Participant Risk Evaluation Enhancements was presented at the 11.7.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). An updated proposal to the Market Participant Risk Evaluation Enhancements from PJM and stakeholders were reviewed at the 11.21.19 and 12.9.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following the 12.9.19 meeting. The proposal for the Market Participant Risk Evaluation Enhancements was voted on following the December 9th task force meeting resulting with 64% support for the PJM package and 97% supporting a change over status quo. The Market Participant Risk Evaluation Enhancements were endorsed at the 3.26.2020 MRC. Final endorsement was also received at the 3.26.2020 meeting of the MC.	Complete
D3	Create internal participant risk management reports that are reliably generated on a periodic basis according to the frequency of opportunities for participants to change portfolio positions.	Credit and Risk Management/Models		Complete
D3.1	Among other measures, include statistical studies of participant exposure, tenor, collateral, MTA, and relationships between these measures.	Credit and Risk Management/Models		Complete

F) Increase the Frequency of Long-Term Auctions
9. PJM Market Design Flaws Gave GreenHat Room to Develop
ID	Recommended Actions	Work Stream	Progress	Completed
F1	Include Long-Term FTRs in monthly or at least bi-monthly auctions.	Market Rules/FTR Product Range	A report to review FTR Performance Improvement Analysis was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A position paper on adjustments to the FTR auction design to mitigate financial risk in the FTR market was presented at the at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Risk Mitigation Senior Task Force – FTR Market Proposal An initial proposal by PJM was presented at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Proposals for the FTR Product Range and Auction Process from PJM and stakeholders were reviewed at the 9.5.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following this meeting. The results of the vote for the FTR Product Range and Auction Process Solutions Package was presented at the 9.24.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The PJM/Vitol Package received the highest level of support with 75% voting in favor of this package. The FTR Product Range and Auction Process package was endorsed at the 12.19.19 MRC. Final endorsement was received at the 1.16.2020 meeting of the MC. On February 14, 2020, in Docket No. ER20-1009-000, PJM submitted proposed revisions to the PJM Tariff. PJM is requesting an effective date of April 15, 2020. PJM received FERC approval on this item with an effective date of April 15, 2020.	Completed
F2	Convene a committee of FTR traders with PJM Credit & Operations to explore new approaches to make more frequent long-term auctions both more efficient to run and as liquid as possible.	Market Rules/FTR Product Range	Stakeholders and PJM were in mutual agreement to retain status quo for this item which was discussed in regards to Stakeholder Governance.	Completed
F3	With expert help, conduct a general review of the FTR market and other PJM markets, to evaluate the risks and rewards of potential structural reforms.	Credit and Risk Management/Models	A report to review FTR Performance Improvement Analysis was reviewed at the 6.25.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). A position paper on adjustments to the FTR auction design to mitigate financial risk in the FTR market was presented at the at the 7.17.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The paper was entitled: Financial Risk Mitigation Senior Task Force – FTR Market Proposal An initial proposal by PJM was presented at the 8.14.2019 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Proposals for the FTR Product Range and Auction Process from PJM and stakeholders were reviewed at the 9.5.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). Voting for this item opened following this meeting. The results of the vote for the FTR Product Range and Auction Process Solutions Package was presented at the 9.24.19 meeting of the Financial Risk Mitigation Senior Task Force (FRMSTF). The PJM/Vitol Package received the highest level of support with 75% voting in favor of this package. The FTR Product Range and Auction Process package was endorsed at the 12.19.19 MRC. Final endorsement was received at the 1.16.2020 meeting of the MC. On February 14, 2020, in Docket No. ER20-1009-000, PJM submitted proposed revisions to the PJM Tariff. PJM is requesting an effective date of April 15, 2020. PJM received FERC approval on this item with an effective date of April 15, 2020.	Completed