The Protocols currently allow ERCOT to assess a fee to eligible Counter-Parties for all or part of the costs of verifying the risk management framework as set forth in Section 16.16.3. The ability to charge and collect a separate fee to account for ERCOT’s risk management verification costs was added to the Protocols with NPRR 438, Additional Minimum Counter-Party Qualification Requirements, Including Risk Management Capability Requirements, which was approved by the ERCOT Board in July 2012. The Protocol language added by NPRR438, however, is not accompanied by a specific fee amount or approved methodology for calculating the fee. As noted in the Impact Analysis for NPRR438, system implementation costs for NPRR438 were immaterial, and the ongoing staffing costs related to oversight of risk management verification should not exceed one Full-Time Equivalent. Following discussion at the November 18, 2013 Finance and Audit Committee meeting, there was consensus that because the overall expenses related to risk management verification are minor, it would be more practical to eliminate the fee and include this expense within ERCOT’s Operations and Maintenance budget. This NPRR removes the language establishing the risk assessment fee from Section 16.16.3.