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CER Update. Industry Governance Group 21 st September 2011. Publications. Work streams. Debt Flagging for Electricity & Gas Customers – Industry Code. Industry Code - Drafting. Drafting – Input from Electricity & Gas Market Participants Office of the Data Protection Commission (ODPC)
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CER Update Industry Governance Group 21st September 2011
Debt Flagging for Electricity & Gas Customers – Industry Code
Industry Code - Drafting • Drafting – Input from • Electricity & Gas Market Participants • Office of the Data Protection Commission (ODPC) • August GMARG/IGG – High Level Aspects • Draft Code – pre Commission approval circulated to Industry & ODPC • Commission approval – Re-circulated • Main points presented today
1. Grounds to Raise a Flag (I) • As per decision; • From when amount fell due, not bill issued, this typically 14 days from bill issued.
1. Grounds to Raise a Flag (II) • Outstanding deposits excluded • Cannot raise a Flag where customer pursuing complaint re monies owed • Must adhere to Industry thresholds & timings • Must issue a flag where relevant criterion per customer category has been satisfied.
1. Grounds to Raise a Flag (III) • Change of Legal Entity (All Customers) • Cannot flag new tenant CoS where debt accumulated by previous tenant • Elec: CoLE signalled on 110 message • Losing supplier cannot raise flag • Inferred CoLE – flag not forwarded to new supplier • Gas: CoLE not signalled → • Options Discussed at August GMARG • ODPC Advice • New supplier ascertain whether new tenant & not yet signed up – if site flagged – flag ignored.
2. Timings • Old supplier to raise flag: • Elec: Lists submitted to MRSO by COB on Mondays & Wednesday • Gas: Within 2 business days • New supplier to decide action • Elec: Within 2 business days • Gas: Within 3 business days
3. Customer Communication (I) • Communication Re Flagging Process • ODPC Advice: Domestic Sign Up Process • Customer must be made of aware of debt flagging at sign up • Notice must be included on domestic customer application forms – online, paper, phone • Terms & Conditions only not sufficient • Tick Box – read & understood notice • Standard wording, otherwise ODPC sign off
3. Customer Communication (II) • Communication Re CoS Cancellation • Within 5 business days; • Gaining supplier issue notification in writing: • CoS request cancelled & why • Advise customer contact current supplier • contact details for MABS or an appropriate alternative, in the case of domestic customers -TBC.
4. Dual Fuel • Dual Fuel – Losing Supplier • Can only flag account which meets the industry debt flagging criterion • Dual Fuel – Gaining Supplier • Where 1 account is flagged and not the other: • Supplier can only proceed with CoS for non-flagged account only if obtained customer agreement to switch for one fuel and not dual fuel • If no agreement obtained, proceed or cancel CoS requests for both accounts
6. Reporting • CER monitoring debt flagging process • On monthly basis, receive from DSOs • # CoS requests flagged by losing supplier • # CoS cancellations following flag • Elec Market Only – • # CoS requests with CoLE • # Debt flags not forwarded to gaining supplier by MRSO due to inferred CoLE • CER conduct spot checks from time to time
Consultation - Background • Current Economic Climate • CER/10/217 Disconnection CoP Guidelines • Keep disconnection to a minimum: Customer must be offered a PPM before a Supplier can request a disconnection • CER/11/106 Debt Flagging Decision • Losing Supplier can flag to gaining supplier where customer debt above industry thresholds • Suppliers concern over compatibility of CER/10/217 & CER/11/106
Consultation - Options • PPM Customer Repaying Debt – 2 Options: • Option A – Status Quo • Customer ceases paying debt when changes supplier - supplier pursues customer for outstanding debt separately • Option B – Debt Travels • Customer must continue to pay off outstanding arrears after they switch supplier
Consultation – Next Steps • Responses due 15th September • Decision Paper issued asap.