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Regulator Seeks Comments on Marketing Standards, Stakeholder Proposals; Includes Requirement For All Door-to-Door Sales To Use Tablet, Be Recorded

February 21, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The Connecticut PURA has sought further comment on proposed marketing standards for electricity supply service.

Last fall, PURA had issued a series of questions, largely focused on potential changes to door-to-door sales, third-party verification, utility rate comparison, agent training and background checks, the timeline for the submission of enrollments by suppliers, and supplier recordkeeping.

PURA is seeking additional comment on several issues raised by stakeholders and on marketing standards previously proposed jointly by suppliers and OCC in 2015 which remain under PURA consideration.

PURA specifically sought comments on:

1. How the supplier-OCC proposed revised Marketing Standards:

     a. Accomplish all of the goals of Conn. Gen. Stat. §16-245o(l)(2), which requires development of, "standards relating to abusive switching practices, solicitations and renewals by electric suppliers, the hiring and training of sales representatives, door-to-door sales and telemarketing practices by electric suppliers."

     b. Take into account consumer protection issues raised in recent supplier enforcement dockets, including:

           • Docket No. 10-01-24RE01, Application of Palmco Power CT, LLC for an Electric Supplier License – Investigation of Marketing and Enrollment Practices;

           • Docket No.14-07-15, PURA Review of Choice Energy, Inc.;

           • Docket No. 06-12-07RE05, Application of Liberty Power Holdings, LLC for an Electric Supplier License – Rebilling;

           • Docket No. 13-02-08, Investigation into Public Power LLC’s Trade Practices; and

           • Docket No. 10-04-03RE01, Application of Choice Energy, LLC’s for an Electric Supplier License – Compliance with Conn. Gen. Stat. §16-245o(g)(1).

2. OCC Comments, p. 21. Comment on OCC’s recommendation that all door-to-door (DTD) sales be recorded on an iPad or similar tablet (as compared to current practice using handwritten documents which are susceptible to forgery or modification).

3. OCC Comments, p. 21. Comment on whether suppliers and their agents always include the Federal Communications Commission (FCC) required notice to customers that sales calls may be recorded.

4. OCC Comments, p. 21. Comment on OCC’s recommendation that all sales calls (including DTD sales) be recorded and kept for a minimum of one year.

5. OCC Comments, p. 23. Comment on OCC’s suggestion that would require marketing materials be updated to include the EDC standard service price within five days of the release of the newest standard service price. Identify what period would be appropriate for written, electronic and verbal (e.g., telemarketing scripts) communications.

6. Supplier Group Comments, p. 17. The Supplier Group states that, “the solicitation process is an opportunity to educate customers.” Comment on best practices to ensure uniformity among all supplier solicitations taking place in the Connecticut marketplace. Do suppliers maintain a uniform script or other supporting documentation to ensure the accuracy of the educational information distributed? Do all sales agents working on behalf of the supplier receive the same script? What controls, if any, are in place to ensure that agents do not go off script?

7. Comment on how PURA can best address reports of spoofing by suppliers and marketers acting on their behalf. Refer to the following: https://www.fcc.gov/consumers/guides/spoofing-and-caller-id.

Docket 14-07-20RE01

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