Following a request from a set of stakeholders for an extension to the time period Ofcom has set for the receipt of responses to the latest consultation document, we have decided to extend the consultation closing period for all relevant parties. The new closing period will now be 8 May 2012. We believe that a 12 week consultation period provides an adequate amount of time for industry stakeholders to complete their review of our consultation and its potential impacts.
As a result of enquiries from a stakeholder in relation to our analysis in the consultation document, three points have been brought to our attention which we would like to clarify for all stakeholders.
It has been brought to our attention that we did not provide a source for the figure of 5 per cent used at paragraph A8.51 for our calculation of harm suffered by consumers who "unwillingly" paid an ETC.
The figure of 5 per cent was derived from further analysis of the proportion of consumers who had paid an ETC but found out about this after the switch had occurred (i.e. 21 per cent as discussed on slide 32. In total 38 respondents incurred an ETC but found out about it after the switch had occurred, 36 of these stated they were happy with their decision to switch. This equates 5 per cent not happy with their decision to switch.
Ofcom stated in p4.156 and 4.161 and A8.51 that approximately 1 per cent of all switchers unwillingly paid an ETC. In fact, 0.14 per cent of all switchers unwillingly paid an ETC (1.1 per cent needs to be multiplied the percentage of switchers who incurred an ETC i.e. 1.1 per cent x 14 per cent). The 1.1 per cent is amongst switchers who paid an ETC (not all switchers).
Note that this is a drafting error only and does not affect the costs used in the impact assessment which are correct.
It has also been noted that we did not reference the source for the 80 per cent figure cited in A8.47.
Ofcom estimated this figure from root cause analysis ('RCA') conducted by OTA which suggested roughly 80 per cent of Erroneous Transfers ('ETs') were accounted for via an agent selecting wrong address whilst roughly 20 per cent was down to other issues (e.g. engineer and CP based errors) which Ofcom estimated were unlikely to be tackled by the Transfer Code ('TxC') process.
This is reflected in the spreadsheet (provided for the Migrations Programme Board 'MPB' meeting on 11 February 2010) in the page titled 'Headline conclusions'. The meeting notes note the RCA in Action 24/1 - Erroneous WLTOs - Urgent Tactical solution required.
In light of the above changes, we would like to offer stakeholders who have (a) responded already and (b) who are planning on responding imminently, two weeks to revise their response on ETCs (revised responses due by 6pm Friday, 25 May 2012). Please direct all changes to firstname.lastname@example.org