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Pennsylvania Finds Retail Supplier's Tablet-Based Door-to-Door Enrollment Process Complies With Regulations

April 24, 2015

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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com

The Pennsylvania PUC issued an order concluding that the door-to-door sales, enrollment, and verification process proposed by IGS Energy complies with 52 Pa. Code § 111.7 and, "is a significant benefit to suppliers and consumers."

IGS's proposed tablet-enabled door-to-door sale process is more fully described in our prior story (click here). In short, rather than the use of a TPV call, verification is performed by having the customer use the tablet to electronically answer the verification questions, with an IGS agent present during the verification.

The PUC's regulations require that for door-to-door sales, the verification process shall be separate from the transaction process and initiated only after the transaction has been finalized. When verifying a transaction that resulted from the agent's contact with a customer at the customer's residence, the verification process shall be initiated only after the agent has physically exited the customer's residence, unless the customer agrees that the agent may remain in the vicinity of the customer during the verification process.

The PUC found that IGS's process complies with these requirements, and noted that such compliance is not specifically the result of the tablet-based process, but because the process separately meets all necessary requirements, including verification.

"Notably, enrolling customers with tablet computers does not exempt IGS from the verification process. The use of the tablet computer is not the key factor in determining whether the verification process is required; the key factor is the role of an agent in the customer's home or on the customer's premises. As such, we conclude that the verification process is relevant to the kinds of sales transactions described in IGS's petition," the PUC said.

The PUC noted that IGS complies with the first part of the verification process by requiring the IGS agent to affirmatively ask the potential customer if the customer consents to the agent's presence. If the customer does not consent to the presence of the agent during the verification process, the IGS agent will immediately leave the premises and the transaction will conclude through a traditional third-party verification telephone call.

The PUC further noted that its regulations do not require that verification be performed by a third party; rather, the regulations merely allow for a third-party to perform the verification.

More important are several enumerated factors listed in the regulations that are required to be included in verifications. "In light of the averments in IGS's petition, it appears that a tablet computer can perform the necessary functions and allow IGS to meet the verification requirements," the PUC said.

The PUC also found that IGS's process, "meets the standard that 'the verification process shall be separate from the transaction process and initiated only after the transaction has been finalized.'"

"We also note and agree with IGS that the use of tablet computers by sales agents coupled with its procedures provide several benefits to both suppliers and customers. The Commission desires to promote the use of new technologies that may improve the customer experience, decrease costs for companies, and encourage greater regulatory compliance. IGS's use of a tablet computer appears to provide most, if not all, of these benefits," the PUC said.

"We welcome the introduction of technological devices or other mechanisms that provide suppliers with greater control and oversight of their sales agents in the field. The GPS-tracking abilities of the tablet computers highlighted by IGS provide several benefits. Tracking and documenting the presence of an agent at the residence of the customer at the date and time of sale will be of great value in resolving any subsequent dispute. A tablet computer also provides greater security for customer information. Through the use of its password- protected tablet computer, it appears that IGS has taken the necessary steps to protect customer information," the PUC said.

The PUC emphasized that its opinion of IGS's sales process relies on the specific facts presented by IGS. Different facts, particularly those involving security of customer data and the verification process, may dictate a different result, the PUC said.

Docket P-2015-2464976

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