FTC to Host Mobile Cramming Roundtable; Protecting Consumers in the Mobile Marketplace; Project No. P134803 #564482-00012

Submission Number:
564482-00012
Commenter:
Chris Witteman
Organization:
CPUC
State:
California
Initiative Name:
FTC to Host Mobile Cramming Roundtable; Protecting Consumers in the Mobile Marketplace; Project No. P134803
Re REFUND RATES -- while we think that refund rates are a very useful and telling metric, the flip side of this is that a liberal refund rate can be used as a shield for fraud. In other words, our experience in some cases is the opposite of Texas/Vermont -- very liberal or "no questions asked" refund rate, used to prevent the issue from being escalated or investigated. Thus rate is still telling. If the carrier/provider refunds 10%, that's still 90% into the bank. Also, as to who owns RISK or CREDIT: what we've discovered (and was discovered in Nwabueze) is that the carriers PURCHASE RECEIVABLES of the aggregator and service/content provider. Finally, the suggestion that CTIA and its members always cooperate with state agencies is somewhat incredible, and certainly doesn't square with my/our experience. Submitted on my own behalf, although I am staff counsel at California Public Utilities Commission (and was on the second panel). Chris Witteman