OEB EBT WORKING GROUP

DATED: / November 21, 2008
WRITTEN BY: / Universal Energy Corporation
TOPIC: / Utility Account Name Changes and Moves
Discussion Paper

(I) INTRODUCTION

A guiding principle of the Electronic Business Transaction (EBT) Standards is to facilitate consumer choice and mobility. More specifically, the intent of the CCL provisions is to ensure that when a customer moves within a distributor’s territory, there is a continuation of service with the same retailer at the new address- i.e. “seamless move”. Similar principles underline the Change Consumer Information (CCI) provisions.

Universal believes that account information changes are not being processed as intended, and as a result customers are being dropped from retailer supply. Universal is requesting a review and amendment of current processes.

(II) BACKGROUND

Issues Discussed October 24, 2008 (as recorded in meeting minutes)

When a customer calls the LDC and requests a name change on the account why is a drop received? Universal has found instances in which we have re-enrolled a dropped customer at the same address either with the spouses name added or when the account holders name was changed to someone else in the household. Universal believes more should be done in way of the LDCs providing retailers with this information.

  • If the account holder calls the LDC and asks to just change their name, then a CCI (or CCL if a move is also involved) should be sent and not a Drop.
  • If the account holder calls the LDC and asks to change the primary account holder to their spouse, a CCI (or CCL if a move is also involved) should be sent and not a Drop.
  • This is because according to the family law (see attachment below), the Retailer contract is binding to both the contract signer and their spouse. The only exception would be if during the contract signing the contract signer specifically states that the spouse is not responsible for the contract.
  • If the account holder calls the LDC and asks to add a co-account holder to the account, a CCI (or CCL if a move is also involved) should be sent and not a Drop.

Response

  • If the account holder and the new account holder calls the LDC to change the primary account holder to the new account holder (provided that the new account holder is not the spouse), then a Drop is sent.
  • If the primary and the secondary account holder calls the LDC to change the secondary account holder to the primary account holder (provided that the secondary account holder is not the spouse of the primary account holder), then a Drop is sent.
  • Barb (OEB) to send Jay (SPi) the board decision around family law.

Proposed Changes for Discussion

The attached compliance bulletin clearly enforces Universal’s view regarding name changes on existing accounts as well as those customers that have moved with the spouse/authorized representative assuming the account at the new location.

The following scenarios should be reviewed once again;

  • If Brad Jones is the account holder and Jackie Jones is added (or for that matter any name is added) a CCI should be sent
  • If Brad and Jackie Jones are the account holders and one is removed, a CCI should be sent
  • If the account is in the name of Brad Jones and switches to Jackie Jones, a CCI should be sent
  • If the account is in Brad and Jackie Jones and goes to Jackie and Brad Jones a CCI should be received; and a CCL in cases where a move occurs
  • Any request to change the account holder information without a move out- a seamless transfer should occur.

During the October 24, 2008 meeting it was discussed that the LDCs would ask the relevant questions when customers request changes to their account. Each scenario identified is resolvable through appropriate inquiries by the LDC csr.

As reference I have attached PIPEDA Section 7.3 for those LDCs that have used privacy legislation as a means of not providing information in circumstances mentioned above.

Reference 1 –

PIPEDA Section 7.3 (b)