At the Market Settlements Subcommittee meeting on January 18, 2018 PJM presented an analysis highlighting the revenues that were returned subsequent to the application of the FTR Forfeiture Rule that was in effect at that time. This analysis shows that there is a significant increase in revenues between 2016 and 2017 that are being taken back from FTR Holders and raises concerns about whether the FTR Forfeiture Rule is achieving its objectives. The sponsors of this problem statement contend that the FTR Forfeiture Rule is overly restrictive and has created barriers for load serving entities to manage their portfolios