Recordkeeping and document retention
Recordkeeping and document retention in Energy, Power & Commodities is governed by a patchwork of overlapping mandates, with the U.S. Commodity Futures Trading Commission, the Federal Energy Regulatory Commission, and the U.K. Financial Conduct Authority each imposing distinct retention schedules, format requirements, and audit-access obligations that do not always align. FERC's recordkeeping rules under 18 C.F.R. Part 125 require physical and electronic records tied to wholesale market activity to be held for specific durations by specific entity types, and CFTC's Part 45 swap data obligations add a parallel layer for firms active in derivatives. Compliance teams in this sector are currently reconciling those requirements against cloud migration projects and third-party trading system contracts, where data custody questions carry direct enforcement exposure.
Watch
- CFTC Part 45 swap recordkeeping amendments: compliance deadlines vary by registrant category
- FERC audit staff requests for trading communications, including instant messages and voice logs
- U.K. FCA's retention overlap with EU REMIT for cross-border energy trading desks
- Cloud vendor contracts that transfer data custody away from the regulated entity itself
Recent material activity in Energy, Power & Commodities
A selection of recent published briefs; this is not a complete archive.
NRC and DOE issue joint environmental clearance for Three Mile Island Unit 1 restart under federal loan guarantee
The NRC, as lead agency, and the DOE Office of Energy Dominance Financing, as cooperating agency, issued a joint environmental assessment and finding of no significant impact on September 25, 2026 for proposed federal ac…
Read a full sample brief →NRC considers license amendment allowing Alternate Concentration Limits at Homestake uranium mill reclamation site in New Mexico
The NRC published notice on September 25, 2026 of an application by Homestake Mining Company of California to amend License No. SUA-1471 for the Grants Reclamation Project near Grants, New Mexico. The amendment would rep…
Read a full sample brief →EPA final rule redefines scope of applicable requirements under Clean Air Act title V operating permit program
EPA's final rule, published September 25, 2026, revises title V operating permit program regulations to codify the agency's existing interpretations of which Clean Air Act requirements qualify as applicable requirements.…
Read a full sample brief →FERC opens scoping period for Tres Palacios Smith Cavern natural gas storage expansion in Texas
FERC opened a scoping period on September 25, 2026 for the proposed Tres Palacios Smith Cavern Expansion Project, a natural gas storage facility in Texas. The notice solicits public and agency comments on environmental i…
Read a full sample brief →FERC opens scoping period for Natural Gas Pipeline of America and Horizon Pipeline North Extension Project
FERC opened a scoping period on September 25, 2026 for the proposed North Extension Project, involving Natural Gas Pipeline of America, LLC and Horizon Pipeline Company, LLC. The notice solicits public and agency comment…
Read a full sample brief →DOE / EIA Energy Policy & Data release pending Cresthaven Analytics full analysis: Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability
DOE / EIA Energy Policy & Data published a regulatory release titled 'Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability'. Cresthaven Analytics…
Read a full sample brief →NRC proposes wholesale revision of reactor licensing, decommissioning, and operational oversight regulations under Executive Order 14300
On September 24, 2026, the NRC published a proposed rule to revise its reactor licensing, decommissioning, and operational oversight regulations. The proposal implements Section 5 of Executive Order 14300, which directs …
Read a full sample brief →EPA reopens public comment on 2024 Texas SIP disapproval covering emissions during power plant maintenance activities
The EPA granted reconsideration on May 11, 2026 of its December 20, 2024 disapproval of a Texas state implementation plan governing visible emissions and particulate matter during planned maintenance, startup, and shutdo…
Read a full sample brief →EPA proposes consent decree setting deadlines for overdue California and Colorado ozone SIP final actions
The EPA published notice on September 24, 2026 of a proposed consent decree in Center for Biological Diversity and Center for Environmental Health v. Lee Zeldin, No. 4:25-cv-10007-JST. The decree would resolve citizen-su…
Read a full sample brief →FERC opens intervention window on Transcontinental Gas Pipe Line Company natural gas pipeline application
FERC published a notice on September 24, 2026 opening the intervention deadline period for a Transcontinental Gas Pipe Line Company, LLC certificate or abandonment application. The notice establishes the procedural windo…
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