COMMUNITIES FOR TELECOM RIGHTS DATA REPORT

August 23, 2006 Summary Draft

CTR DATABASE INTAKE REPORT: The following report includes intakes from 2004 through August 20, 2006. This report includes both Latino and API CTR intakes and contains a chart representing the specific 2004- current "Service Types as an overview to the specific details portrayed by the "Issue Types" and corresponding intake totals to determine the underlying complaint problems. This report includes a separate consumer education breakdown for purposes of determining the actual needs of LEP consumers as compared to needs assessments and materials previously devised and issued by the CPUC.

MOST PROMINENT CTR DATABASE SERVICE TYPES AND NUMBERS:

Service Type Total API LIF

Bundled Plan	48 62 70
Company Calling Care	26 16 10
Consumer Ed	2946 2180 766
Contract Cellular/Wireless	1474 708 666
Dial-Around	13 3 10
High-Speed Internet	77 57 20
Internet Dial-Up	167 123 44
Pager	3 2 1
Prepaid Wireless	52 27 25
Prepaid Calling Cards	142 112 30
Residential Bundled	171 102 69
Residential Local	2238 1596 642
Residential Local Toll	76 60 16
Residential Long Distance	1272 912 360
ULTS	297 283 14
Wireless Abuse/ Service	167 98 69

CHART SUMMARY: Although Residential Local, Residential Long Distance and Consumer Education appear to reflect the highest numbers, overlaps discussed above and a review of the details of each intake, show that the most prominent CTR database complaint service types are wireless contract and kiosk problems. The Residential services should not have included "Bundled Services" as a choice because a review of each complaint shows tremendous overlapping of other choices. Local Toll problems resulted from a few customers failing to switch it to new carriers. However, a high portion of Local Toll validated complaints were minimum monthly fees charged by a major carrier to customers that verifiably did not have service with the carrier for 3-4 years. This problem was most prevalent in 2004, decreased in 2005 and decreased again in 2006. The company's continued explanation was a computer glitch. Dial-up Internet resulted in a more than acceptable number of modem hijacking and one ISP unilaterally utilizing toll numbers to connect under the auspices of programmed local numbers being busy. Finally, Long Distance issues other than slamming and cramming were a combination of prepaid calling cards not working and customers not understanding plan restrictions omitted in the marketing campaigns.

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MOST PROMINENT CTR DATABASE ISSUES AND CORRESPONDING NUMBERS: The most prominent issues are represented by the database complaint numbers. Several "issues" overlap into other areas. For purposes of objectivity, the overlapping issues and corresponding numbers listed below would increase the numbers in the count section. Examples of this overlapping immediately follow the "Issues"chart.

Issues Count

Billed After Cancellation	193
Collect Call	48
Collection Notice	119
Contract Change W/out Notice	65
Contract Extension Renewal	102
Cramming	498
Debt Collection	88
Double-Billing	103
Early Termination Fee	84
Failure to Refund /Credit	77
Faulty Equipment	89
International Calls	163
Language Accessibility-Billing	618
Late Fees	20
Media Downloads	30
Misleading Ads	95
Misrepresentation	20
Number Portability	5
Operator Assisted	160
Poor Coverage	40
Promotion/Award Not Honored	65
Reconnection Fee	17
Repairs/Installation	240
Roaming Charges	41
Rude Customer Service	412
Slamming	388
Taxes, Fees & Surcharges	139
Telemarketing	840
Timely Billing	22
Unclear Billing Format	225
Undisclosed Fees	35
Unusual or High Costs	585
Wrong Rate	135
Wrongful Disconnection	33
Unrecognized Call/Number	298

SUMMARY OF ABOVE CHART: The above chart numbers must be interpreted by understanding combined database issues. The combinations and numbers are listed as follows:

Collect Call, Operator Assisted, Unrecognized Call/Number and Wrong Rate = 641

Double-Billing, Undisclosed Fees, Unclear Billing Format, Timely Billing = 385

Billed after Cancellation, Contract Change without Notice, Contract Extension=360

Collection Notice, Debt Collection and Wrongful Disconnection = 240

The majority of Residential Long Distance complaints involved slamming (non-subscriber acceptance and access to verification tapes denied) and third party billing aggregator charges = 876

****Language Accessibility/Billing numbers support CTR's position that language barriers leave LEP consumers at an unfair advantage. CTR data also supports the In-Language Draft Report issued by the California Public Utilities Commissions

The primary victim demographics by ethnicity are ranked in order and show the most prevalent groups in the CTR database. It should be noted that Latinos comprise the largest ethnic group listed below in the state of California:

Latino: Vietnamese

Chinese: Filipino

Hmong Cambodian

Korean Others

Victim Demographic by Language: 9/1/04-8/22/06: Spanish, Hmong, Cantonese, Korean, Tagalog, Vitenamese, Cambodian/Khmer, Laotian, Other

MOST PREVALENT ISSUES IMPACTING LATINO & API CONSUMERS:

Failure of marketing materials to disclose contract terms

¬ Telemarketing, billing inserts and advertising in the target languages fail to provide disclosure of terms and conditions that impact actual agreements. Company marketing costs far outweigh any expenditure to provide one or more documents in target languages. The CTR one-page Plan Checker form would be such a minimal translation cost in comparison to marketing materials that it becomes an issue of a choice to do so or not. Companies could jointly translate the one-pager and then place their company logos at the top for distribution to kiosks or stores.

Misrepresentation at wireless kiosks

¬ Wireless kiosk transactions continue to be the leading source of misrepresentations and other problems that cause CBOs, consumers and companies additional time, money and frustration.

Bills require Ph. D. to read

¬ Billing formats are difficult for both API and Latino consumers.

Low CSR help for API speakers

¬ Spanish customer service reps are more available than API in-language company customer service reps due to the 14-15 different API languages.

Prepaid phone card problems bigger for API consumers

¬ Prepaid phone cards are clearly a larger problem for API consumers than for Latinos per the CTR data. The Filipino consumers reflect an overwhelming majority of prepaid phone card complaints.

Internet and media download cramming higher for API consumers

¬ Internet data and media download cramming was considerably higher for the API consumers than for Latinos. This issue was also widespread amongst mainstream consumers. CBOs and all but one company have been working together to block Internet access and to "unsubscribe" vendor services, as needed. CBOs advised consumers that wanted the services, to request "plan subscriptions". Prior to CBO intervention and calling supervisors of companies, API and Latino subscribers were regularly disconnected and sent to collections.

Refusal of carriers to help consumers with stolen phones

¬ Primarily one large wireless company regularly refuses to accept/record reports of lost or stolen phones. Customers are told they are too late if reports are made based upon the next month's billing statement. If these phones are not in use, the customer would have no way of knowing the stolen phone was used by an unknown party. Similar incidents do occur with other carriers. However, most supervisors and/or executive contacts have been resolving these issues during recent months of 2006. (Current example: CTR Korean CBO has had no success resolving a case where a Korean woman hired Spanish-speaking movers. Her next month's bill reflected $6,000 owed for calls to Guatemala. The woman and her family only speak Korean- March - August 2006 and resolution is unknown. Customer service was extremely rude to CBOs and to lead agency.)

Text messaging complaints higher in Filipino communities

¬ Text messaging problems are predominantly noted in Filipino CBO intakes.

Fraud higher at API than Latino kiosks

¬ Kiosks catering to API communities have demonstrated higher instances of fraud than Latino kiosks. This database result may be due to more API CBOs than Latino.

Confusion about ULTS continues

¬ Even though ULTS consumer education has been ongoing by various CBOs throughout the state under the leadership of one organization, the majority of CTR consumer education issues reflect continued confusion about this program, its requirements and new regulations.

Discrimination against accents
* CTR continually experiences rude customer service as a result of the sound of an

"accent" with English-speaking customer service reps. In most cases, CTR still

finds that most calls to customer service are not logged.

Editorial Note: PUC In-Language Report proves need for CTR

The CPUC In-Language Draft Report supports the fact that market competition and mutual cooperation efforts with consumer education will force companies to prioritize customer relations. CTR data highly questions The "Report". Specifically, CTR is concerned about some of the report facts supporting actual facts:

1. Only 100 companies out of approximately 1500 voluntarily returned the PUC-requested surveys. Of the 100 surveys returned, gas & electric and water districts were included.

2. It is unclear as to how the CPUC can get caught up on almost 30,000 backlogged complaints while spending all of its staff time compiling other data and writing reports.

. 3. If the complaint system is designated for completion by the end of 2007, CTR is unclear as to how many more complaints will be backlogged in addition to the 30,000 that now exist.

4. Finally, commissioners promised that CTR would meet with all carriers to establish a complaint process for CBOs by June 2006. To date, AT&T and T-Mobile complaint processes are completed. CTR has not had any further communications with other carriers except Verizon Wireless (several meeting dates postponed and no pending new date).

5. With these few facts, CTR is concerned that time spent on marketing the idea of consumer education is being substituted for actual complaint resolution, monitoring and reporting as a means of determining and remedying problem company practices.

CTR legacy is proof that LEP telecom complaints exist

CONCLUSION: The results of this initial draft report are designed to show the importance of accurate and validated complaint intake. A renewed focus on complaint intake, consistant online validated complaints filed with the CPUC and the ongoing monitoring and tracking of CTR complaints appear to be the only real proof that California LEP consumer problems exist. CTR can leave a legacy to show the legislature and consumers that market competition does not solve existing and will not solve future consumer telecom problems.