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PUCT Staff Seek Commission Guidance on Prepaid Disclosure Statement Threshold Issues
September 9, 2011
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PUCT Staff have sought Commission guidance on three threshold issues in current project 39357 to develop a standard Prepaid Disclosure Statement (PDS).
See 7/25 for stakeholder positions on various PDS issues
Specifically, Staff sought Commission feedback on TDU fee disclosures, standard form language, and territory-specific Prepaid Disclosure Statements.
Regarding specific utility fee disclosures, Staff outlines the options as follows:
1. Require REPs to disclose applicable standard discretionary service charges for move-ins, priority move-ins, standard switches, self-selected switches, disconnections and reconnections as proposed;
2. Require REPs to disclose applicable discretionary service charges for the "typical" utility charges, such as standard move-ins at an existing self-contained meter, priority move-ins at an existing self-contained meter, standard switches, self-selected switches, standard disconnects at the meter, and standard reconnects at the meter;
3. Require REPs to disclose applicable discretionary service charges for "typical" utility charges associated with starting prepaid service, such as standard move-ins at an existing self-contained meter, priority move-ins at an existing self-contained meter, standard switches, and self-selected switches, or
4. Do not require the disclosure of discretionary service charges.
Regarding a notice that TDU fees may apply to the initial prepayment, Staff outlined the options as follows:
1. Require REPs to disclose that utility-fees may apply and indicate whether such fees will be paid in addition to the costs of enrolling in prepaid service or subtracted from the customer's account balance as proposed; or
2. Do not mention utility-fees on the PDS at all
Regarding language for the Prepaid Disclosure Statement, Staff outlined the options as follows:
1. Require REPs to use the standardized language as proposed;
2. Require REPs to use the standardized language as proposed, but allow for additional information to be disclosed in an italicized font below the required standardized language in each section of the form;
3. Allow the REPs selected flexibility, such as the ability to develop their own disclosure language for payment verification, descriptions of deferred payment plans and additional communications methods; or
4. Adopt the format and headings of the form, with the proposed language for "illustrative purposes. " This would allow REPs to develop their own language in compliance with the minimum requirements for the PDS outlined in Subst. R. 25.498(e). REPs would still be required to reproduce the text labeled "Important Notice About Prepaid Electric Service" verbatim and in the same sequence as set forth in the form
Regarding whether a single Prepaid Disclosure Statement may be used for all service areas, Staff outlined the options as follows:
1. Allow REPs the choice of whether they create a single PDS for all utility service areas, or for each utility service area in which they offer prepaid service, as proposed; or
2. Require REPs to create a separate PDS for each utility service area in which they offer prepaid service
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