ISO-NE proposes Financial Assurance Policy (FAP) revisions for participants that are determined to  t have adequate corporate liquidity relative to potential obligations that may be incurred
under the pay for performance (PFP) construct of Forward Capacity Market (FCM).  Beginning with the 2025 – 2026 Capacity Commitment Period, ISO-NE will perform a corporate liquidity assessment on each FCM participant holding a CSO (or its guarantor, if such guarantor is guaranteeing the payment of PFP penalties), to determine its ability to pay potential penalty payment obligations associated with its CSO within the applicable Capacity CCP , over a forward-looking rolling six months.  “Low risk” participants will continue to be subject to the current FCM Delivery Financial Assurance methodology; “medium and high risk” participants will be subject to higher collateral requirements (risk adders).  A February 1, 2025, effective date is proposed.