PIAC’s submission was supportive of the proposed business-to-business procedures for new and original retailers to follow when a customer indicates they have been transferred without explicit informed consent. Where it is demonstrated that customers have not provided their explicit informed consent to a transfer, the Draft Rule voids the new contract and requires the original retailer to take back the customer on the original contract. PIAC strongly supported this change as it is consistent with community expectations of remedies available for the improper or unauthorised action of a third party, but would like to see the Draft Rule extended to also restore customers to the existing rebate, hardship and existing payment plan arrangements they may have had prior to the transfer. PIAC also welcomed the proposed prohibition on disconnecting customers who transferred without consent within 12 months. However, PIAC considered the issue to be more nuanced and suggested the AEMC to consider the implications for customers who were unknowingly transferred in error and therefore unlikely to contact their new retailer to rectify the issue.
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