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Retail Supplier Seeks Waiver To Allow Enrollment Via "Digital" TPV

March 5, 2018

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Copyright 2010-17
Reporting by Paul Ring •

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Direct Energy filed at the Public Utilities Commission of Ohio to request waivers of certain rules governing the third-party verification (TPV) process for new customers enrolled through sales channels requiring TPV.

The requested waivers would enable Direct to offer customers the ability to complete the verification process through a digital confirmation platform.

Direct said that the proposed digital confirmation process will function much like traditional voice TPV. The main difference is that the verifier’s interaction with the customer will occur through text or internet prompts rather than voice communication. Direct said that digital TPV works as follows:

a. At the conclusion of a door-to-door sale for CRES or CRNG service, as well as a telephone sale of CRNG service, the Direct salesperson will advise the customer of the option to complete third-party verification by either voice or digital confirmation.

b. If the customer chooses digital confirmation, the salesperson will initiate an email or text to the customer. (the customer will not be able to initiate TPV until the salesperson leaves the property.)

c. When the customer clicks the link in the email or text, they will be taken to a location permission and identity authentication page. The customer will be asked for consent to share their location and enter his or her name to identify his or her enrollment record. A geolocation feature built into the digital TPV platform will prevent the customer from starting the verification process until the salesperson has left the property.

d. Once the customer’s identity and location have been verified, the customer will be presented with the list of disclosures and consents required under the Electric TPV Rule and/or Gas TPV Rule. The customer must select 'Yes' or 'No' in response to each verification question. The pictures at this link show how digital TPV will look to the customer (the content of these images is for illustrative purposes only)

e. At the end of the verification questions, the customer will be provided with a final confirmation of his or her decision to switch, and e-sign the verification form.

f. The customer will then see a 'Thank You' page, and a 'Welcome Kit' email will be sent automatically to the customer.

g. Within the Welcome Kit, the customer will receive a signed copy of the contract and another disclosure of his or her right to cancel within the applicable time period.

h. Direct will maintain digital TPV records under the same rules and standards applicable to voice TPV.

Direct Energy said that the digital TPV provides enhanced customer protections versus the standard telephonic audio TPV

"For example, under the current rules, neither Direct nor the third-party verifier are able to confirm whether the sales agent has left the customer’s property. With digital TPV, Direct is able to identify the location of both the sales agent and the customer in real-time. A distance alert function automatically blocks the enrollment if the sales agent is within a predetermined area of the customer. The distance alert function will also stop attempted enrollments where the customer’s location does not match the service address provided," Direct said

"Similarly, under the Commission’s rules, voice TPV requires the verifier to disclose a significant amount of information. Digital TPV allows the customer to complete the verification process at his or her own pace, which maximizes the opportunity for comprehension. The customer is able to read and, if necessary, re-read the verification questions, rather than listen to them once," Direct said

Direct Energy said that it would offer customers the choice of digital TPV or traditional voice TPV.

Direct sought waivers of various current rules which make reference to an "audio" recording, a "telephonic" process, and "verbal" questions

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