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Follow us on LinkedIn and @ RFirst_Corp onTwitter. # RF W orkshop. Understanding the Enforcement Process. Patrick O’Connor – Counsel, RF Maxwell Reisinger – Associate Counsel, RF. Objectives. Gain a better understanding of the life cycle of a violation

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  1. Follow us on LinkedIn and @RFirst_CorponTwitter #RFWorkshop

  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

  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

  5. Lifecycle of a Violation

  6. PV Identification & Screen

  7. Risk Assessment & Mitigation Review

  8. Disposition

  9. Ineffective Self-Report Example

  10. Effective Self-Report Example

  11. Ineffective Mitigation Plans

  12. Tips for Effective Mitigation Plan Milestones

  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

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