PENOYAR, J.
¶ 1 The Washington Utilities and Transportation Commission (WUTC) enacted two new rules creating reporting requirements: (1) the Cash Transfer Rule, requiring noninvestment grade utilities to give WUTC five days' notice before making large cash transfers to its subsidiaries or affiliated companies; and (2) the Subsidiary Reporting Rule, requiring all regulated telecommunications companies to file annual reports describing nearly all transactions between...
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