It is likely that a new REC Schedule will be introduced to set out the arrangements for the Market Stabilisation Charge. As this is a temporary measure, this will make it easier to remove the arrangements from the REC when they are no longer required. Changes may be required to the Main Body of the REC to the extent that we wish to ensure existing discretionary remedies such as the application of interest to late payments will be triggered in the event of late payment of a MSC invoice. It may also be appropriate to ensure that there is a clear process and timeline for the a late payment being considered an event of default. Amongst other potential actions, this may allow for RECCo to issue an instruction to the CSS not to register any further supply points to the defaulting party. Given the nature of the MSC and the risk that Ofgem is seeking to mitigate through its introduction, it may be appropriate for that process and timeline to be firmly established prior to the scheme going live. RECCo will be required to procure certain services, which will include the provision of reports to calculate the MSC, and potentially the invoicing function itself. The default cost recovery mechanism as set out under Clause 9 of the REC would recover these costs from all suppliers as part of their general RECCo contribution. That may still be necessary and appropriate, though there is also a potential to recover these MSC related costs from domestic suppliers only. If that option is progressed, a change to the Charging Methodology Schedule would be required. We understand that Ofgem will procure an independent party to carry out periodic audits of the operation of the MSC scheme. Subject to confirmation of the scope of that audit, it may therefore not be necessary for RECCo to procure an audit as part of the arrangements it is putting in place. In order to avoid any delays in the provision of data, it may be prudent for the Change Proposal to explicitly require relevant parties to grant the data controllers and/processors permission to share the data with RECCo (and/or its appointed agents) for the purpose of administering the MSC scheme. As the MSC will be administered on a monthly cycle rather than the usual RECCo quarterly cycle, it may assist parties if we provide additional certainty through the publication of an invoice schedule. For instance this could be based on: • The reports from service providers within [5] WDs of the end of the month; • Invoices issued within [10] WDs of the end of the month; • Suppliers to have [1 month] payment terms (i.e. payment due circa [6] weeks from end of the relevant period; • Interest applied to any late payment from [1]WD after the due date; • Any late payment not received within a further [15] WDs (i.e. the second week of the following month when MSC invoices are again being prepared) will be escalated to an event of default, notified to Party and PAB; • If payment not received within [X WDs] from notice, PAB will consider event of default and unless evidence of extenuating circumstances will issue instruction to CSS to cease registrations for that party. As it will take on addition role(s) including being the body to determine any disputes raised in relations to the Scheme, the PAB Terms of Reference may require revision. It is also likely that a bespoke disputes process will be developed.