4
Accounting for the effects of rate regulation
Description
of the Matter
As disclosed in note 7 of the consolidated financial statements,
the Company has $3.4
billion in regulatory assets and $1.9 billion in regulatory
liabilities. The Company’s rate-
regulated subsidiaries are subject to regulation by various
federal, state and provincial
regulatory authorities in the geographic regions in which
they operate. The regulatory
rates are designed to recover the prudently incurred costs
of providing the regulated
products or services and provide a reasonable return on
the equity invested or assets, as
applicable. In addition to regulatory assets and liabilities,
rate regulation impacts multiple
financial statement line items, including, but not limited to,
property, plant
and equipment
(“PP&E”), operating revenues and expenses, income taxes,
and depreciation expense.
Auditing the impact of rate regulation on the Company’s
financial statements is complex
and highly judgmental due to the significant judgments
made by the Company to support
its accounting and disclosure for regulatory matters when
final regulatory decisions or
orders have not yet been obtained or when regulatory
formulas are complex. There is
also subjectivity involved in assessing the potential
impact of future regulatory decisions
on the financial statements. Although the Company
expects to recover costs from
customers through rates, there is a risk that the regulator
will not approve full recovery of
the costs incurred. The Company’s judgments
include making an assessment of the
probability of recovery of and return on costs incurred, of the
potential disallowance of
part of the cost incurred, or of the probable refund of
gains or amounts previously
collected from customers through future rates.
How We
Addressed
the Matter in
Our Audit
We performed audit procedures that included,
amongst others, assessing the Company’s
evaluation of the probability of future recovery for regulatory
assets, PP&E, and refund of
regulatory liabilities by obtaining and reviewing relevant
regulatory orders, filings,
testimony, hearings
and correspondence, and other publicly available
information. For
regulatory matters for which regulatory decisions or orders
have not yet been obtained,
we inspected the rate-regulated subsidiaries’ filings for
any evidence that might contradict
the Company’s assertions, and reviewed other regulatory
orders, filings and
correspondence for other entities within the same or similar
jurisdictions to assess the
likelihood of recovery or refund in future rates based on
the regulator’s treatment of
similar costs under similar circumstances. We obtained
and evaluated an analysis from
the Company and corroborated that analysis with letters
from legal counsel, when
appropriate, regarding cost recoveries, gains or amounts
previously collected from
customers or future changes in rates. We also assessed
the methodology,
accuracy and
completeness of the Company’s calculations of regulatory
asset and liability balances
based on provisions and formulas outlined in rate orders
and other correspondence with
the regulators. We evaluated the Company's
disclosures related to the impacts of rate
regulation.
Fair Value (“FV”) measurement of derivative
financial instruments
Description
of the Matter
Held-for-trading (“HFT”) derivative assets of $270 million
and liabilities of $690 million,
disclosed in note 16 to the consolidated financial statements,
are measured at FV.
The
Company recognized $207 million in realized and unrealized
gains during the year with
respect to HFT derivatives.
Auditing the Company’s valuation of HFT derivatives
is complex and highly judgmental
due to the complexity of the contract terms and valuation models,
and the significant
estimation required in determining the FV of the contracts.
In determining the FV of HFT
derivatives, significant assumptions about future economic
and market assumptions with
uncertain outcomes are used, including third-party sourced
forward commodity pricing
curves based on illiquid markets, internally developed correlation
factors and basis
differentials. These assumptions have a significant
impact on the FV of the HFT