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Regulator Seeks Comments on Sought Changes to Recent Decision on Retail Supplier Marketing Standards, Sales Practices
The Connecticut PURA has sought comment on a joint application by retail suppliers and the Office of Consumer Advocate to revise marketing standards and the disclosure statement applicable to electric suppliers as adopted in Docket 14-07-20.
As previously reported, suppliers and OCA have jointly developed changes to the standards recently adopted by PURA. Such changes largely relate to the current contract assignment requirements, and door-to-door sales requirements.
Click here for background on the proposed OCA/supplier changes
Among other things, PURA sought comment on:
• Assignment of customers. Comment on the likelihood that customers proposed to be assigned from one licensed supplier (Supplier) to another may overlook or discard letters they receive from a Supplier with whom they have no current contractual relationship.
• Assignment of customers. Comment on the proposed assignment clause that would permit Suppliers to disclose and implement "more favorable pricing terms."
• Assignment of customers. Comment on customers' opportunity to effectuate a switch or decline the assignment if notice is provided only ten days before such assignment.
• Door-to-Door Sales. Comment on provisions that can be implemented to the door-to-door sales process that can eliminate or significantly curtail instances of customer allegations of forgery.
• Telemarketing Procedures, Caller ID and Caller Introduction. Comment on requiring Suppliers and their authorized agents to include as the Caller ID-displayed number the phone number to contact the Supplier.
• Telemarketing Procedures, Responsibility to Provide. Comment on requiring Suppliers and their authorized agents to record every marketing or solicitation telephone call, with such recordings maintained in accordance with applicable law and submitted to the Authority upon request.
• Enrollment Process. PURA has received complaints in which customers report enrolling with a supplier several days in advance of the next scheduled meter reading date (First Meter Reading Date) to effectuate a switch on the First Meter Reading Date. The customer subsequently learns that the enrollment was not timely processed and thus the switch did not occur as anticipated. But the enrollment is processed, and the switch is effective, on the customer’s subsequent meter reading date (Second Meter Reading Date). As a result, the customer does not enroll with the new supplier as anticipated and remains with the supplier he was attempting to drop or remains on Standard Service longer, and pays more for generation services, than anticipated. In some cases, missing the enrollment on the First Meter Reading Date results in an automatic enrollment to a fixed rate contract with the then-current supplier which contract includes early termination fees; a situation the customer attempted to avoid by switching on the First Meter Reading Date. The Authority has also responded to customers who were not timely notified about an enrollment that was rejected by the EDC because it contained incorrect information (e.g., wrong account number) which error results in the customer missing an enrollment on the First Meter Reading Date or, in some cases, not being enrolled or notified. With this backdrop, describe the current standards for processing residential and business customer enrollments. Separately, discuss the role that the three-day rescission requirement required under Conn. Gen. Stat. 16-245 plays in the enrollment process and discuss the varying circumstances related to online enrollment vs. an enrollment that requires third-party verification or an in-person (e.g., door-to-door) enrollment. Also discuss enrollments that are rejected due to incorrect information and the standards that should be applied in these cases. Identify the minimum/maximum time it should take to process an enrollment and timelines for notifying customers about enrollments that are rejected. What standards should PURA consider to assure timely customer enrollments?
• Minimum consumption requirements. PURA has received complaints regarding rejection of an otherwise valid enrollment based on low consumption. Comment on whether a minimum consumption threshold is allowable and/or appropriate for residential and/or small business customers.
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April 7, 2015
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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com
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