Pa. PUC Staff Reminds Retail Suppliers Of Regulations Requiring Specific Intro For Door-to-Door Sales, Telemarketing
Says Phrases "Working With" Utility, Opening By Asking "Check Your Bill" Are Inappropriate, Possibly Contrary To Regulations
February 4, 2020 Email This Story Copyright 2010-20 EnergyChoiceMatters.com
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During a recent Pennsylvania PUC CHARGE (Committee Handling Activities for Retail Growth in Electricity) conference call with various members of the PUC Staff, the PUC's Bureau of Consumer Services reminded retail energy suppliers of specific regulations governing introductory statements in door-to-door sales and telemarketing, and said certain phrases are inappropriate and are possibly contrary to such regulations.
Staff noted that 52 Pa Code § 111.9 is "very specific" as to how a retail energy agent is to introduce themselves to a potential customer:
The regulation provides that when engaging in door-to-door sales or marketing activities, an agent shall comply with the following:
(1) "After greeting the customer, the agent shall immediately identify himself by name, the supplier the agent represents and the reason for the visit. The agent shall state that he is not working for and is independent of the local distribution company or another supplier."
(2) "The agent shall offer a business card or other material that lists the agent’s name, identification number and title, and the supplier’s name and contact information, including telephone number..."
The telemarketing regulations contain similar requirements
Staff said that it receives reports of the use of opening statements such as, "May I see your bill? I am here to check your bill to make sure you are receiving the discount/rebate you are entitled to."
Such statements are inappropriate and possibly contrary to the above-mentioned regulations, Staff said
Staff also reported that the PUC occasionally receives reports of agents misrepresenting themselves as being affiliated or "working with" the local utility, which Staff said is also inappropriate and possibly contrary to the above-mentioned regulations
Staff also provided further guidance and reminders regarding door-to-door marketing
• Suppliers are advised to contact local authorities to let them know who you are and what you are doing (some municipalities have permit ordinances that require this). Local ordinances supersede PUC Chapter 111 regulations.
• All door-to-door agents must have criminal background checks (including the 'Megan’s Law') performed prior to being on the street. See 52 Pa. Code § 111.4
• 52 Pa Code § 111.14 requires suppliers to notify the Commission and the local utility of door-to-door operations. The notices should include geographic location (municipalities) and dates of operations.
Staff urged all suppliers, when using vendors to perform door-to-door and/or telemarketing, to closely monitor the vendor and to have quality assurance mechanisms in place.
Staff asked any supplier who is considering door-to-door marketing for the first time to reach out to Staff for a briefing on the door-to-door marketing rules.