Still Cramming after all these Years?

Chris WittemanCalifornia Public Utilities Commission*

wit@cpuc.ca.govNASUCA Presentation

*for identification purposes only

What We’re Talking About

System Architecture

Confusing Bills

Confusing Bills -- No Service Provider Listed

Complaint Tracking Issues

Consumer Rage– www.consumeraffairs.

com

– www.ripoffreport.com – www.complaintsboard.

com

– www.classactionconnect.com

 

Charles Young says: I have landline phone service and DSL with AT&T. I pay for my long distance service on a separate bill. My AT&T bill this month included $8.44 for ILD Teleservices.I called AT&T and informed them that I did not order or want any services from or through AT&T other than DSL and landline phone. I asked them to remove the charges and block all future third party charges.The customer rep replied that I have to call ILD Teleservices to cancel my service, and that AT&T is unable to block third party services.As I explained to the rep, I did not order anything from ILD Teleservices, I do not know what ILD Teleservices is, and I should not have to call some unknown third party to correct my AT&T bill.

The Run-Around

Brenda of Fairfield, CA June 10, 2010

Upon receiving this month's AT&T billing, we are again charged 13.21 for May. After you credited the account for the previous 25.90 for March and April to cancel the unwanted service. I'm not sure of what part of we did not ask for or request this service you understand. PLEASE DISCONTINUE THIS SERVICE IMMEDIATELY AND CREDIT FOR THE MONTH OF MAY FOREVER. I don't want to do this each month. I am also again contacting Consumer Affairs and AT&T of this unfair business practice via this e-mail. I do not understand why consumers must go through this each month to cancel a service we did not request.

Repeat request to agent

Cal PU Code 2890

• (a) A telephone bill may only contain charges for products or services, the purchase of which the subscriber has authorized….

• (d) (1) A billing telephone company shall clearly identify, and use a separate billing section for, each person, corporation, or billing agent that generates a charge on a subscriber's telephone bill.

CPUC Cramming Actions

– ATN – D 98 03 039– USP&C – D.01-04-036 - aggregator, later

Mafia indictment– ASI DSL – D.02-10-073 – unauthorized DSL

charges - $27 million settlement– MCI settlement – approved in D.06-04-035– Americatel Investigation – I.10-02-003

Enforcement problems/defenses

• Counting problems – how many victims?• Consumer confusion about responsible

parties• “call detail record” defense• Blame-it-on-the-telemarketer defense• Anyone-in-house-can-authorize defense• Conflict of interest – billing telcos,

aggregators

Solutions

• **Third-party bill block**• Hold billing telcos responsible• Clean up reporting

– Audit, Enforce, (Clarify?)• Remove presumption that CDR = authorizn• More TPVs, Better TPVs (whole sales pitch)• More Enforcement

Network Architecture

network architecture Service/content provider ↔ Aggregator ↔ Billing Telco ↔ Customer

$$ flow right to left

re tracking credits and debits through the foodchain