01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the What Settlement Information is Posted section (3).
SRP recommends BPM 207 include a comprehensive list of all settlement information that will be posted.
03: Please supply any comments related to the How Settlement Information is Accessed section (4).
SRP encourages the WPP to consider providing information in regards to how the WRAP Settlements Interface Guide is accessed.
04: Please supply any comments related to the Timeline section (5).
To facilitate existing monthly accounting practices, SRP requests that monthly settlement prices and accompanying details will be calculated and posted no later than four (4) business days following the Program Administrator’s receipt of all the required input data. A four (4) business day timeline has the potential to accommodate widespread accounting practices of all participants.
05: Please supply any comments related to the Timeline - Unavailability of external Input Data section (5.1).
SRP requests clarity regarding any authority of the Program Administrator to utilize alternative data in the event of unavailable data. For example, is a BPM 206 change required when the Program Administrator’s data source has missing data for one interval?
SRP requests clarity on whether the Program Administrator assessment would ever determine that alternate data should not be utilized in the event of unavailable data, including examples of how calculations would proceed if the Program Administrator assessment does not determine that alternate data should be utilized while external Input Data is unavailable.
06: Please supply any comments related to the Timeline - Changes to Inputs after Settlement Values have been Calculated section (5.2).
SRP recommends the WPP elaborate on the recalibration process and provide clear step-by-step guidance for participants to follow when submitting a request to recalculate the settlements. The guide should detail any required documentation.
07: Please supply any comments related to the Dispute Resolution Process section (6).
SRP requests the WPP incorporate examples or hypothetical scenarios of typical settlement disputes and the steps for resolutions to provide participants with insight to successfully navigate the dispute resolution process.
General Comment
SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.