8. Carrier Identification in Bills

Identifying the carrier that is billing or serving a customer is essential to evaluating claims of unauthorized billing or customer transfer. Customers are billed based on corporate names that may be abbreviations or fictitious business names. When the customer calls to complain to the Commission staff, this sketchy information is insufficient to identify a particular Commission-certified carrier. Staff proposed that each billing carrier include its Commission-assigned Utility Number (U#) in all bills and printed materials, including advertising.

Several parties, including MCI and GTE contended that Staff's proposal would be too expensive because it would require a California-specific bill and advertising. Pacific Bell agreed that the advertising requirement was unwarranted but supported Staff's recommendation that the U number appear on bills and letters of authorization.

We agree with Staff that the carrier identity is essential for effective consumer complaints and protection. Consumers most often complain when wrongfully billed or when their service has been transferred. Requiring the Utility Number on bills and service transfer documents (letters of authorization) will allow Commission consumer services staff to assist the consumer in resolving the dispute with the correct carrier.

In the comments on the Draft Decision, CALTEL objected to this requirement and contended that it would cause carriers to create expensive California-specific billing systems and transfer procedures. CALTEL also pointed out that the FCC was considering a similar unique identifier.

As an initial matter, we have no objection to relying on an identification system initiated by the FCC so long as it provides customers and our consumer services personnel accurate and readily available identification information. As for the expense of including the Utility Number or other unique identifier, we are not persuaded that conveying the most basic of information to consumers, i.e., the exact identity of the service provider, is an unreasonable burden. As noted elsewhere, through the use of abbreviated names and fictitious business names, consumers may receive little or no useful identity information about their service provider. Absent this most basic information, consumers are simply in no position to accurately determine whether they authorized the charges.

Moreover, we note that the rules we adopt today for tracking consumer complaints require that the local exchange carriers have some means of identifying all service providers for which they bill, directly or indirectly. Thus, the creation of the unique identifier is a necessity; the only remaining question is whether to share this information with consumers.

Our CSD staff also raised the issue of carriers using fictitious business names without registering those names with the Commission. The use of fictitious business names is not prohibited by statute or Commission policy. Nevertheless, when a carrier operates under a name other than the name on the operating certificate, consumers can become confused and may have a difficult time filing a complaint against the proper carrier at the Commission.

In comments on the Second Draft Decision, several parties objected to creating a unique identifier for billing purposes. Sprint, MCI and AT&T point out that numbers convey no useful information to consumers and that most large interexchange carriers bill under their own recognizable name. CALTEL and TRA note that § 2890, effective January 1, 2000, requires that all consumer bills for telecommunications service include the identify of each service provider. CALTEL and TRA conclude that Commission could best serve consumers and carriers by requiring carriers to bill under the name by which they are certificated.

We agree. The actual identity of the service provider is the information that should be readily available to consumers. Therefore, we find that all certificated service providers must bill customers using the name which appears on their Certificate of Public Convenience and Necessity. Any abbreviations must convey enough information to allow the consumer and the Commission staff to identify the carrier.

Requiring billing by certificated name only is consistent with § 2890 and also obviates the need for any registry of fictitious business name as ORA requested.

This requirement, however, does not address service providers that are not certificated by this Commission. For these service providers, we will require that the bill display the name under which the service provider is certificated by the FCC, if applicable, or its legal name, disregarding any fictitious business names. Our objective here is to provide consumers useful information about the identity of the service provider that has billed the consumer.

Each service provider's identity must, however, be unique. This will require that the Billing Telephone Companies coordinate the exact name which appears on the bill.

For these reasons, we will order the Billing Telephone Companies to submit a plan for requiring all service providers which use their billing and collections services to provide a unique identifier based on certificated name or business name, if not certificated, for inclusion in the bill and to tabulate consumer complaint rates on a provider-by-provider basis. Where the service provider is a Commission-certificated carrier, the unique identifier shall be based in the name as it appears on the carrier's Certificate of Public Convenience and Necessity. Where the service provider is not required to be certificated by this Commission, the Billing Telephone Companies and the service provider shall base the identifier on the name under which the service provider does business with consumers and shall maintain a comprehensive list of all such identifiers, which will be provided to staff on a regular basis.

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