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Another Retail Supplier Seeks Waiver Of Certain TPV Requirements

March 8, 2018

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

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AEP Energy has filed a petition with the Public Utilities Commission of Ohio for waivers of certain of the current third party verification requirements for door-to-door electric and natural gas sales so that customers may complete verifications on their own smart devices or via email.

Generally, AEP Energy's process would rely on the customer using a personal electronic device to receive and consent to various disclosures, including specific product information, and enrollment. AEP Energy would then conduct a shortened telephonic TPV which would not include the more granular information disclosed and affirmed by the customer through the electronic device, but would still record, among other things, the customer's personal information, and confirmation that the individual is the account holder or is authorized to switch the account

AEP Energy in the petition said that its current business plan is to use direct employees paid on an hourly and commission basis and trained by AEP Energy supervisors as field sales agents.

Such agents will have a GPS and internet-enabled computer tablet for use in conducting sales transactions.

AEP Energy said that it is using a new technology for its door-to-door sales process, which provides the ability for customers to use their own smart devices, such as iPhones, Androids, or similar devices, or via email to their personal computers to execute and sign off on many aspects of the legal and regulatory safeguards in the existing TPV enrollment process.

AEP Energy field agents will conduct their sales presentation and record the customer's responses. The tablet script will prompt the field sales agent to verbally inform the customer of various disclosures and provisions, including the right of rescission.

At the conclusion of the sales presentation, the field sales agent will explain to the customer that the customer will be sent a text message or email and verification link asking the customer for approval to send a text message or email to complete the enrollment process. The field sales agent will explain that if the customer accepts the verification link, the customer will be directed to a link for verification of the customer's name and an authentication page. The link will then prompt the customer to enter their last name and will then be disclosed enrollment information obtained from the customer during the field sales presentation. Once the sales agent verifies that the customer has received the text message or email and verification link, the field sales agent will by way of a warm down conversation respond to the customer if the customer has any issues in completing the disclosure statements. Once the customer responds and submits the completed disclosure statements, a third party verification call will be initiated and the field sales agent will leave the property of the customer.

Through an Order Verification Form set forth in the computer tablet application, the customer will review and acknowledge their personal information and the product offering they have selected. Customer will respond to a series of yes/no questions on their personal communications device, similar to the questions posed in the typical TPV process. These questions will cover most of the disclosures currently required by the TPV process. "However, this new technology approach will enable the customer to see, read and acknowledge such informational disclosures on their own personal communication devices. The customer would be verifying and acknowledging the information required by their electronic selection of an answer. These proposed questions will then not be repeated in the TPV process, resulting in less time on the phone for the customer," AEP Energy said

The customer will verify, acknowledge, and confirm the following through the yes/no questions on their personal communications device:

• Customer phone number

• Service address

• Mailing address

• Email address

• Receipt of residential terms & conditions for enrollment terms

• Receipt of AEP Energy welcome brochure confirmation

• Ability for AEP Energy to send email notifications regarding account confirmation

• Understand AEP Energy will be energy/gas supplier and it will take 1-2 billing cycles for enrollment completion

• Electric or gas supply rate

• Understand any applicable utility charges and state and local taxes may also be applied to monthly bill

• Term of contract

• Early termination fee, if applicable

• Utility will continue to deliver electricity/gas, read meter, handle emergency care and send monthly invoices

• AEP Energy's charges will be a separate line item on utility invoice confirmation

• Inquire if customer wants to enroll on AEP Energy's Budget Billing Program, if available and if not available, that budget billing for the generation or gas supply portion is not offered

• Percentage of renewable energy provided and REC specifications if customer elected a renewable energy offer

• Contract may automatically renew on month to month variable price or under new terms with conditions with prior written notice to the customer

• Customer account number

• Rescission information, if applicable, and utility phone number for rescinding contract; and

• Statement that customer will receive letter from utility regarding switch to AEP Energy.

If a customer responds with a "No" response to a question in which a "Yes" response is expected, a pop-out window would appear with a further explanation of the question and an invitation to change the response if desired. If the customer does not change their response, the enrollment would not be completed, a TPV call will not be triggered, and therefore, the sale is not valid.

After the customer responds to all of the yes/no questions, the customer will receive a call from a third party verification agent, who will have access to the customer's responses. Upon receipt of such call, the field sales agent will leave the customer's premises for the duration of and after the third party verification call. This allows the customer to make their final selections without the field sales agent being present. The shortened TPV process would then follow in which the third party verification agent would obtain the customer's acknowledgment and confirmation of the following:

• Ability to record call;

• First and last name;

• Account holder identity;

• If not speaking to the account holder, if person is spouse or holds power of attorney to authorized switch provided by the account holder;

• AEP Energy is an independent seller and customer can remain with utility or other supplier;

• AEP Energy's sales representative has left the property; and

• If the field sales agent provided or emailed the customer with signed enrolled terms and welcome brochure.

The tablet computer has a Global Positioning System (GPS) mechanism that tracks the exact time and location of a customer enrollment and retains detailed records of the same. The GPS in the computer tablet tracks the time and location of all customer solicitations made by AEP Energy's field sales agents, regardless of whether a customer is enrolled with AEP Energy. When a customer is enrolled with AEP Energy, the customer's own communication device then verifies the customer's consent to the terms and conditions

AEP Energy's field agents computer tablet verifies via an electronic signature that the customer consents and acknowledges the specific statements set forth in OAC 4901:1-29- 06(D)(6)(A) acknowledgment form. This process also gives the customer the option to receive a physical copy of the terms and conditions and applicable acknowledgment form. The consented to terms and conditions are either physically provided to the customer at the time of sale or, upon the customers verified consent, emailed to the customer's inbox immediately upon the customer enrolling in the CRES and CRNG product.

AEP Energy is not seeking waiver of the TPV rules for any door-to-door enrollment where such customer does not have a personal communications device, such as an iPhone or Android, capable of receiving the electronic messaging or an email and accessing the provided hyperlinks to the verification process.

See more details on AEP Energy's process, including scripts for the process, here

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