Retail Supplier Seeks Waiver of Audio TPV Requirement

United Energy Trading, LLC d/b/a Kratos Gas and Power petitioned the Public Utilities Commission of Ohio for a waiver of certain audio recording requirements set forth in Ohio Administrative Code (OAC) 4901:1-29-06(E)(1) with respect to third party verifications for door-to-door sales, so that it may use a web-based app to verify enrollments

Kratos said that it plans to modernize its door-to-door interaction by contracting with an outside vendor to provide a web-based third-party-verification application process. Instead of using a clipboard and paper, the sales agent will enter a customer’s name, address, email address, and account number on a tablet or other mobile device.

Under this process, the customer will electronically sign for the enrollment directly on the sales agent’s device, and elect to verify the enrollment via mobile phone text or email

After the sales agent completes the face-to-face interaction, independent verification will be sent to the customer’s phone or email address in accordance with the customer’s selection. The text or email will contain a verification link. Once clicked, an interface will appear that will direct the customer through and permit the customer to acknowledge or answer, as appropriate, the information in OAC 4901:1-29-06(D)(6)(b). Enrollment is completed only upon the customer signing electronically and tapping the submit button.

After submission, the customer receives a confirmation number with links to Kratos' Terms and Conditions and other useful correspondence, which the customer may choose to print or download. The confirmation screen will advise the customer that the incumbent natural gas carrier will send a confirmation notice of the transfer of service and that the customer may rescind the enrollment within the date of the postmark of such notice by contacting the incumbent natural gas company.

Kratos said that its process produces a verification record which includes time and date stamps for when the sale was made, when it was signed, and a geo-tagged location of the customer

Kratos said that the app process will comply with the other consumer protection rules and requirements set forth in OAC 4901:1-29-06(E) and 4901:1-29-06(F) as well as other applicable state and federal consumer protection rules and statutes.