FCC Bureau Strictly Enforcing TPV Requirements
Since 1998, the FCC has adjudicated individual consumer claims that the consumer’s telecommunications services were switched without authorization (aka “slamming”). These adjudications often are released by the dozens and use a consistent format and language. The most recent batch of such releases confirms that, when it comes to orders confirmed by third party verification (“TPV”), the Bureau employs a literal interpretation of the content requirements for verification.
Continue reading to see examples of the Bureau’s literal interpretations.
Among the findings made by the Bureau in recent orders are:
1. The TPV must identify each telephone number “to be switched.” In America Net, “the verifier recited a list of telephone numbers presumably associated with the business, but did not specifically elicit the ‘telephone numbers to be switched.’ ”
2. The TPV must verify the subscriber’s “intent to change” his preferred carrier. In Business Network, the TPV stated that the purpose of the call was to “verify and confirm your account information” but did not state that the verification was to change the carrier. Similarly, in Silv Communications, the verifier stated the the TPV was for “quality control and accurate data entry” but did not explicitly state that its purpose was to authorize a carrier change.
3. The TPV must confirm authorization to “make a carrier change.” In Teledias Communications, the TPV asked whether the subscriber was authorized “to make this selection” and the FCC found the verification lacking because it did not ask the person if they were making a change in providers.