Retail Supplier Seeks Rules Waiver To Offer Digital TPV

February 19, 2021

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Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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RPA Energy, Inc. d/b/a Green Choice Energy (RPA Energy) petitioned the Public Utilities Commission of Ohio for waivers of certain rules governing the third-party verification (TPV) process for new customers enrolled through sales channels requiring TPV. The requested waivers will enable RPA Energy to offer customers the ability to complete the verification process through digital confirmation

RPA Energy said that its waiver request is the same or substantially similar to the waivers requested and approved in Case No. 18-0382-GE-WVR (Direct Energy), Case No. 18- 0371-EL-WVR (AEP Energy), and Case No. 18-0604-GE-WVR (Constellation).

RPA Energy said that it requests a waiver of the Electric TPV Rule and Gas TPV Rule to give customers the option of third-party verification through a digital confirmation platform developed by a third-party vendor. Customers will continue to have the option of traditional, telephonic TPV, the supplier said

"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," RPA said

RPA described the process 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 RPA Energy 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. (As discussed below, 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.

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. RPA Energy will maintain digital TPV records under the same rules and standards applicable to voice TPV.

"Digital TPV not only dramatically simplifies and expedites the verification process; it enhances the customer experience, while simultaneously bolstering RPA Energy’s ability to identify and prevent fraudulent activity, as well as the Commission’s ability to investigate complaints and monitor compliance with applicable rules," RPA said

"For example, under the current rules, neither RPA Energy nor the third-party verifier are able to confirm whether the sales agent has left the customer’s property. With digital TPV, RPA Energy 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," RPA 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," RPA said

"Digital TPV also makes it easier for customers who feel they were put on the spot or pressured by a sales agent to back-out of an enrollment. Rather than saying 'No' to the sales agent or verifier, the customer may decline the enrollment during the digital verification process or elect not to start or complete the verification," RPA said

Among the specific rules for which RPA sought a waiver are (electric rules quoted, similar rules applicable for gas):

• The CRES provider must retain the audio recording of the customer's enrollment for one year after the contract with the customer is terminated

• To enroll a residential or small commercial customer telephonically, a CRES provider shall make a date and time stamped audio recording verifying before the completion of the telephone call, at a minimum, all of the following...

• Various rules which require a "verbal" statement and customer's acknowledgement of the TPV questions/answers

Case No. 21-0157-GE-WVR

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