Texas Retail Provider Proposes "Two Step" (Dual Validation) Process For Electronic Door-to-Door Enrollments

TXU Energy has proposed a "two-step" or "dual validation" process for door-to-door enrollments completed through electronic devices.

TXU's comments came in response to Staff and stakeholder strawman proposals on such enrollments.

"One notable addition suggested by TXU Energy is a requirement that customers engaging in electronic enrollment via hand-held device in a door-to-door solicitation setting must enter some type of unique identifier or password, known only to the customer, both before the enrollment disclosures and upon completion of the enrollment process. This would help ensure that customers are present for the entire enrollment process and would effectively provide the same level of protections that telephonic verification provides today," TXU said

"As an example of how this process would work, if the customer or applicant consents to using an electronic device to conduct their door-to-door enrollment, the door-to-door agent would be required to hand the device to the customer or applicant and allow them to enter some type of unique identifier or password which would be encrypted and known only to the customer or applicant. At the conclusion of the enrollment process, after the customer or applicant provides their electronic signature confirming their enrollment, they would again be required to enter the same unique identifier or password to confirm they have fully completed the enrollment. If the two verification entries do not match, then the enrollment may not be submitted for a market transaction," TXU said

"This 'two-step' or 'dual validation' process ensures that if an applicant or customer were to begin an enrollment, but at some point walk away before it is completed, it would be difficult for the agent or another person to surreptitiously and improperly complete the enrollment because that individual would not have access to the customer or applicant's password or unique identifier," TXU said

TXU proposed the following language for the rule, "if the customer or applicant is enrolling electronically through a door-to-door solicitation at the customer's or applicant's residence, the REP or aggregator shall prompt the customer or applicant to securely and without agent assistance enter a unique identifier or password into the device both prior to the presentation of the enrollment disclosures and again to end the enrollment. The enrollment shall be considered valid only if the application software confirms that the unique identifier or password entries match."

Project 45625