UCAN's reply comments [1] support a strong reporting requirement for telecommunications abuses, something the Cellular Telephone Industry Association(CTIA), AT&T, Verizon and other carriers don't want. These proceedings will decide if the companies will have to comply with basic consumer protection standards, or will be allowed to police themselves.
Companies prefer a requirement where they decide if a third party for whom they bill is a "bad actor," and then report that to the California Public Utilities Commission. The problem is, the companies proposals entirely ignore their own, in-house billing fraud abuses. In its reply comments [1] UCAN debunks the carriers hollow proposals, and offers a balanced, efficient alternative for consumers.
From the reply comments:
"The comments to the Commission's ACR were largely to be expected. Wireless and wireline carriers generally minimize the prevalence of cramming complaints, and point to the market as the solution to any existing problems with cramming. They present an alternative proposal to report on carrier action against "bad actors," rather than specific customer complaints. Consumer advocates have highlighted the importance of thorough cramming reporting requirements to the Commission's regulatory and enforcement responsibilities. Fortunately we do not have to make policy in a vacuum and guess at the results. The developments in telecommunications in this decade, particularly in the wireless industry, coupled with deregulation efforts, have led to a tremendous variety and amount of cramming. The cramming problem is real, yet there is severe lack of systematic data collection to understand the complete impact that cramming has on the consumer, and the primary culprits and causes of cramming.