9. Slamming Record-Keeping

Pacific Bell recommends using the Utility Number to clarify the identity of carriers transferring customers. Using electronic messages, interexchange carriers are able to direct local exchange carriers to transfer customers from one interexchange carrier to another. Not all interexchange carriers have obtained a unique code (Carrier Identification Code, CIC) which the local exchange carrier uses to keep track of all the different interexchange carriers. The carriers that do not have a unique code are always resellers who rely on the code of their underlying wholesale carrier. This code is the basis of the local exchange carriers' record keeping of disputed customer transfers. Where a reselling carrier does not have a unique code, the local exchange carrier cannot maintain accurate records about that particular carrier's customer dispute rate. In this way, resellers can shield their dispute rates from the local exchange carrier as well as the Commission.

Two proposals were discussed. The first proposition is to require each and every interexchange carrier to obtain its own CIC. While sounding simple, Pacific Bell stated that requiring every carrier to have a unique CIC "would require the replacement of almost all of Pacific Bell's switches in California and would cost more than we can estimate at this time." Pacific Bell Comments at 8. Assuming that Pacific Bell's seemingly extreme estimate is correct, the proposal is not feasible.

The second proposal is to use the Utility Number to differentiate among all the carriers which do not have CICs. Pacific Bell states that they could implement such a change for between $200,000 and $500,000.

Because complete and accurate records are essential to the Commission enforcement staff discharging their duties, we will order the local exchange carriers to implement this change. Carriers submitting customer transfers will be required to identify themselves by their Utility Number, if they do not have a unique CIC. The local exchange carriers will use this information to maintain customer transfer dispute rates on a carrier-by-carrier basis.¹⁷