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Follow us on LinkedIn and @RFirst_Corp onTwitter #RFWorkshop Forward Together ReliabilityFirst Understanding the Enforcement Process Patrick OConnor Counsel, RF Maxwell Reisinger Associate Counsel, RF Objectives Gain a better


  1. Follow us on LinkedIn and @RFirst_Corp onTwitter #RFWorkshop Forward Together • ReliabilityFirst

  2. Understanding the Enforcement Process Patrick O’Connor – Counsel, RF Maxwell Reisinger – Associate Counsel, RF

  3. Objectives  Gain a better understanding of the life cycle of a violation  Provide clarification on each step in ReliabilityFirst’s Enforcement Process • Explain and define commonly used terms in the Process  Give tips for effective Self-Reports, Mitigation Plans, and Evidence Verification submissions 3 Forward Together • ReliabilityFirst

  4. Enforcement Philosophy  Message • Focus on reliability through a commitment to continuous improvement, strong management practices, and effective compliance programs  Actions • Incent desired behavior ‒ Penalty offsets ‒ Favorable processing treatment (e.g., Compliance Exception) • Discourage undesired conduct ‒ Monetary penalties ‒ Sanctions ‒ Enhanced compliance monitoring 4 Forward Together • ReliabilityFirst

  5. Lifecycle of a Violation 5 Forward Together • ReliabilityFirst

  6. PV Identification & Screen 6 Forward Together • ReliabilityFirst

  7. Risk Assessment & Mitigation Review 7 Forward Together • ReliabilityFirst

  8. Disposition 8 Forward Together • ReliabilityFirst

  9. Ineffective Self-Report Example 9 Forward Together • ReliabilityFirst

  10. Effective Self-Report Example 10 Forward Together • ReliabilityFirst

  11. Ineffective Mitigation Plans 11 Forward Together • ReliabilityFirst

  12. Tips for Effective Mitigation Plan Milestones 12 Forward Together • ReliabilityFirst

  13. Tips for Evidence Submissions  Quality of Information • Start with a narrative description • Organization is key • Clarity • Focus on two-fold task of mitigation  Overall Strategy • Opportunity to improve overall reliability, security, and resilience 13 Forward Together • ReliabilityFirst

  14. Questions & Answers Forward Together ReliabilityFirst 14 Forward Together • ReliabilityFirst

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