ILD Telecommunications

ILD

Consumer Protection Standards of Practice

In order to protect consumers from unauthorized, deceptive or ambiguous charges on their telephone bills, ILD Telecommunications, Inc. has adopted and agreed to be bound by the following Consumer Protection Standards of Practice developed by the Coalition to Ensure Responsible Billing (“CERB”).  ILD requires its merchant-customers to adhere to and be bound by these consumer protection standards.

PRE-SCREENING OF PROVIDERS AND SERVICES

ILD commits to pre-screening all prospective service providers and the programs, products and services they offer.

SCREENING OF PROVIDERS
ILD will require as a precondition for any business relationships the following information:

  • Service provider company name and address.
  • Names of officers and principals of the company.
  • Proof of corporate or partnership status.
  • Copies of certifications as required.
  • Foreign corporation filings as required.
  • Any information regarding whether the company, its affiliates and/or its officers or principals have been subject to prior conviction for fraud or have had billing services terminated.
  • That any tariffs be made available on request.
  • The names, addresses, officers and principals of any telemarketing companies to be used by the service provider.
  • The names, addresses, officers and principals of any third party verification companies to be used by the service provider .

SCREENING OF PROGRAMS, PRODUCTS AND SERVICES
ILD will require the following information to be provided:

  • Marketing materials.
  • Advertisements (print or other media).
  • Applicable fulfillment package (which must include cancellation information if not included elsewhere and a toll free customer service telephone number).
  • Scripts for both sales and validation.
  • Honest, clear and understandable text phrase for telephone bill.
  • Prior notification of any material change in the above information.

ILD will not knowingly provide billing for services employing the following practices:

  • Box, sweepstakes, or contest-type entry forms.
  • Negative option sales offers, including negative option "free trial" periods.
  • 800 pay per call.
  • Collect callback.
  • Phantom billing (charging for calls never made or services never provided).
  • Such other programs, products or services ILD determine to be deceptive or anti-consumer.

ILD will maintain an internal standards committee to review the information collected for both providers and programs. ILD does not maintain vested sales interest in the acceptance of a service, product or program.

COMPLIANCE MONITORING

In order to better police the business practices of its service providers and to assure the efficiency of its screening procedures ILD commits to engage in active monitoring of providers and programs. ILD will:

  • Monitor consumer inquiries.
  • Monitor consumer complaints to government agencies.
  • Monitor escalated complaints to the local exchange carrier.
  • Maintain up-to-date records regarding complaints and inquiries.
  • Adopt action plans to respond to complaints and inquiries.
  • Notify service providers of complaints or inquiries.
  • Coordinate investigations with service providers.
  • ILD shall take such disciplinary action as each determines is appropriate under the circumstances.

MANDATORY AUTHORIZATION

It is critical that consumers can depend upon their authorization for the service, product or program for which they will be billed. Verification of authorization must be available from service providers, on request, for a two-year period.

ILD will require service providers to employ one of the following forms of authorization, subject to applicable law:

  • Letter of authorization or sales order, or
  • Recorded independent third party verification, or
  • Voice recording of telephone sales authorization.

A valid authorization must include:

  • The date.
  • The name, address and telephone number of the consumer.
  • Assurance that the consumer is qualified to authorize billing.
  • A description of the product or service.
  • A description of the applicable charges.
  • An explicit consumer acknowledgement that the charges for the product or service will appear on the telephone bill.
  • A toll free telephone number that subscribers may call to make inquiries concerning the service.
  • The acceptance by the consumer of the offer.

In addition, authorization verified by an independent third party must include:

  • An initial statement that the purpose of the verifications is to confirm the consumer's intention to accept the sales offer.
  • A statement that the service provider is not affiliated with a LEC, where there is no affiliation.
  • A unique consumer identifier.
  • A review by third party personnel of the entire verification where the verification is automated.

An independent third party verifier must meet the following criteria:

  • It must be completely independent of the service provider and the telemarketer.
  • It must not be owned, managed, controlled or directed by the service provider or the telemarketer.
  • It must not have any financial incentive in the completion of the sale.
  • It must operate in a location physically separate from the service provider and the telemarketer.

CONSUMER-FRIENDLY BILLING PRACTICES

Central to a consumer's right to ensure that they have not been crammed is the ability to understand and read the telephone bill. ILD agree that informed consumers can better protect themselves from unauthorized products or services. ILD will support providing consumers a bill that can be easily understood.

Consumer bills should include:

  • A clear identification of the billing entity.
  • A clear identification of the service provider.
  • A clear description of products or services.
  • A clear identification of the charges.
  • The toll free telephone number that subscribers may call to make inquiries concerning the billing.

CONSUMER SATISFACTION

Consumers must be able to easily and quickly discuss problems. ILD are committed to monitoring consumer satisfaction particularly with regard to any disputes or inquiries that may arise. ILD will provide quick and thorough responses. ILD shall provide on request:

  • The name, address, phone number and fax number of the service provider.
  • The nature of any charge.
  • The method of authorization.
  • Information as to how a consumer may cancel a service or product.

In addition, in order to facilitate resolution of disputes ILD will:

  • Provide a toll free customer service number.
  • Provide dedicated staff to respond to consumer inquiries.
  • Provide a full and timely investigation of any dispute.
  • Initiate a credit or respond to the consumer within 30 days of the consumer's dispute.

DISCLOSURE

ILD may share with each other and, upon request, will provide federal and state enforcement agencies with the following information:

  • Identifying information with respect to terminated service providers and programs.
  • A description of specific practices relating to cramming that the ILD have encountered, and the steps being taken by the ILD to correct them.
  • Aggregate data with regard to complaints filed with federal and state government authorities received by ILD.

ILD is a member of The Coalition to Ensure Responsible Billing, which was formed by the United States' leading billing clearinghouses in an effort to combat consumer fraud on the local telephone bill.