procedure several elements relied upon past verify authority person signing password application 1 direct knowledge individual signing energy community relatively small cases personal knowledge person signing behalf counterparty done business past 2 ostensible authority 3 3 rd party verification 3 rd party verification following procedure used credit legal contracts departments approved counterparty online transactions main reception number applicant company called senior contact trading department requested vice president director trading requested verification pa signatory authorized person bind company master agreements online contracts commodity trading purposes company informed phone call recorded date name title phone number person verifies applicant recorded three places 1 access tracking database 2 online trading operations control form 3 recorded telephone conversation master user id forwarded customer upon verification authority applicant