In retail energy, the rules for verifying a supplier switch come from each state, and a state can set different rules for each sales channel. There is no national checklist to copy. This page covers how to map your own footprint, the two buying criteria the rules point to everywhere, and what our agent does on a switch verification.
The TPV Buyer's Checklist
What to measure, and what to make any TPV vendor prove, including us.
Whether a supplier switch needs third party verification, what the call must confirm, and how it must be run are decided by each state. A state can set different rules for door-to-door, telemarketing, online and event sales, and the rules change.
A requirements table on a vendor's website, ours included, is the wrong place to get them from. So this page does not list states. It lists the five things to map for every state and channel you sell in, with your counsel, and then to put in front of every vendor you are considering.
Fill these in for each state and channel you sell in. Where an answer is unclear, that is a question for counsel before it is a question for a vendor.
Which channels need independent verification, what the call must confirm, whether another method such as a written or electronic authorization is allowed instead, and how soon after the sale verification has to happen.
Ask the vendor: show us, state by state and channel by channel, how your workflow meets each one.
Who may run the verification, how separate it has to be from the sales agent, and whether the verifier's pay can depend on the outcome.
Ask the vendor: who controls the verifier, and what is it paid per? A verifier paid per confirmed enrollment has a financial reason to confirm.
How long recordings and verification records must be kept, and how quickly you must produce them when a regulator or a customer asks.
Ask the vendor: how fast can we retrieve a specific call, in what format, and what happens to the records if we leave?
Recording-consent rules differ by state, and some require every party's consent. The verification should say the call is recorded at the start, wherever you sell.
Ask the vendor: where in the script is the recording notice, and what happens if the customer objects?
The customer's right to cancel after enrolling: how long it lasts, when it starts, and how the verification has to describe it.
Ask the vendor: does your script read each state's rescission terms exactly as approved, and how is a change to them versioned?
Both come from the federal telecom rule (47 CFR 64.1120), where TPV started. They are the right standard for energy whether or not your states spell them out.
If the sale happened in Spanish, the verification should too. A customer confirming terms in a language they did not buy in is a rejection or a dispute waiting to happen. When a customer needs a language your program does not cover, the verification should stop and say why.
An automated verifier should let the customer reach a live person at any time during the call. A customer who asks for a person and cannot get one either abandons or gets talked into an answer, and neither outcome helps you.
A single completion rate hides three different results. On an energy enrollment program they look like this.
The call ends before a defensible decision. Watch it at peak times, door-to-door evenings and campaign pushes, when verification queues back up. Some of these are valid switches lost. You want this low, and you want the exact step where people leave.
The customer does not understand they are switching supplier, thinks it is a discount from their utility, or will not confirm the rate type and term. That is the verifier doing its job. A rejection rate near zero means the control never fires.
A switch recorded as confirmed when the customer on the recording did not agree. In energy it surfaces later as a rescission, a complaint or a regulator's question, and the recording is the evidence.
The enrollment arrives from your system with the details the state's script needs: the account, the supplier, the rate and term, and the rescission language. The agent reads the approved disclosures for that state and channel word for word, answers questions only along the clarification paths you approve, and handles customers who answer like people rather than like a keypad.
When an answer is not a clear yes, it rejects the verification, escalates it for review, or transfers the customer to a live person. Every attempt comes back with the recording and a structured result: the outcome, the answer to each question, and where and why a verification stopped.
How the agent works, and the five things to make any vendor prove
In some states and for some sales channels, yes, but not everywhere and not in the same way. Requirements are set state by state and can differ for door-to-door, telemarketing, online and event sales, so map each state and channel you sell in with counsel.
It depends on the state. Common elements include the customer's identity and authority over the account, the account details, the supplier's name and the fact that a switch is taking place, the rate and its type, the term and any fees, and the right to cancel. Your state's rules and your counsel set the exact script.
Where the rules allow it. Some states specify how verification must run for a given channel, so check each one. In telecom, the federal rule expressly allows automated verification with conditions (47 CFR 64.1120), which is a sensible standard to require of any automated verifier. As of this writing we have not seen a regulator publish rules written specifically for AI verifiers.
It depends on the state, and the periods change, so we do not publish a number. Map retention and production timelines for each state you sell in, and ask every vendor how fast you can retrieve a specific call and what happens to the records if you leave.
If you sell in Spanish, verify in Spanish. Same-language verification is required for telecom carrier changes and is the right standard for energy whether or not your states spell it out. If a customer needs a language your program does not cover, the verification should stop and say why.
We do not publish prices, and most vendors in this category do not. We price per attempt, so a rejection costs us nothing. How to compare TPV pricing.
Bring it to a vendor call: the number that matters, the nine numbers to make any vendor separate, the five things to make them prove, and the two questions that sort vendors fastest.
Tell me what you verify and roughly how many a month, and I will reply by email. If you would rather talk it through, pick a time on my calendar.
Pick a time on my calendar
Ryan Schuetz
Founder, Automatdo