FERC accepts changes to the FAP (eff. Sep 1, 2025), that: (i) adds two new circumstances under which ISO-NE may draw upon a Market Participant’s letter of credit (“LC”) (“Risk  Mitigation Draws”); (ii) modifies the eligibility criteria for banks that issue LCs to ISO-NE; and (iii) conforms several other provisions regarding the forms of acceptable financial assurance.