Retail Energy Regulator Approves One Change In TPV Script, Denies Other Sought Changes

In response to a motion for clarification from Vistra Corp., the Connecticut PURA adopted a single change to the third-party verification (TPV) script that retail suppliers must use under PURA's Marketing Standards, but denied other sought changes

Vistra sought approval to make certain changes to the third-party verification (TPV) script for existing customers enrolling onto new products

Vistra had said that the required script contains language that is applicable only to new enrollments, such as confirmation that the customer authorizes a change in supplier. In cases where a supplier’s existing customers wish to remain with their supplier and execute a new agreement for a different product, this TPV script could result in customer confusion as the customer is not making a change to their supplier, Vistra said

Vistra had proposed several changes to reflect situations in which a TPV is conducted for a change in product, but the supplier does not change

PURA only approved one of the proposed changes

"After review of Vistra’s suggested changes on page 2 of its Motion, the Authority partially approves and partially denies Vistra’s modifications. The TPV script was adopted for customer protection and even if some sections seem repetitive it is important to include with each and every customer. Therefore, the Authority does not approve Vistra’s suggested changes for paragraphs 2, 4, 5, or 6. The Authority does approve the modifications in paragraph 11," PURA said

"Vistra shall continue to use the TPV script as adopted in the Decision, except for the modification in paragraph 11 in the limited purpose of reenrollment of an existing customer," PURA said

Specifically, for product changes, PURA struck certain language from paragraph 11, with the revised question now reading (removed text shown as strikethrough text): Ask, "Are you aware that by authorizing this transaction, you confirm that you are entering into a contract with [Electric Supplier], which changes your electric generation service to [Electric Supplier]." (Have customer respond that they understand yes/no).

However, the TPV script still requires the use of the paragraph stating, "Confirm the customer on the call is authorized to change the generation service provider on the electric bill (Person on the call must state their relationship to or employment position with the customer listed on the bill)." Vistra had proposed that the phrase "provider on the electric bill" be replaced with "product", but this change was rejected

Additionally, the TPV script retains the requirement that, "Confirm the name of supplier making the offer and that the customer understands that the supplier is a third-party not affiliated with the customer’s utility (Customer must respond yes/no)." Vistra had proposed removing this paragraph entirely for a product change

Furthermore, the TPV script retains the requirement that, "Confirm customer’s account number, name, service address, and telephone number (The customer must read the information directly from their bill; the TPV provider cannot read the information to the customer and receive a yes/no response)." Vistra had proposed just asking for the account number and service address for a product change, stating that the other sought information is redundant of information already collected from existing customers and would serve only to cause inadvertent TPV failures or customer frustration and/or confusion as to why the supplier does not already have that information on file.

Docket No. 14-07-20RE01