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STEP

ACTION

1

  • Does the customer’s concern warrant Compliance’s involvement?

    • If yes, go :

      • Collect and consolidate as much information/proof as possible

      • Go to Step 2

    • If no, follow appropriate process(es) and Stop

2

  • Seek approval to notify Compliance:

    • Internal Comment:

      • Summarize the matter

      • Provide a brief overview of actions taken during your investigation

      • Note any relevant findings/discoveries (e.g., reviewed WC, etc.)

      • If provided, provide proof/documentation shared

      • Request approval to involve Compliance

    • Tag: Cassandra Mercado, Sabin Abad

    • Go to Step 3

3

  • Was approval received by a Team Supervisor?

    • If yes,

      • Update the EBH ticket status to: “Waiting on Compliance

      • Go to Step 4

    • If no, follow appropriate process(es) and Stop

Info

Note: Updating the EBH ticket status will create a duplicate, linked POLICY ticket in a separate project: EB Compliance. This will allow you to facilitate conversation internally with the Compliance team. When customer interaction is necessary, it would be done via the original Support ticket.

4

  • Locate the linked POLICY ticket created

  • Update the ticket:

    • Reporter: Aileen Kozlowski

    • Request Participants: Steven Edwards, Christopher Strain, Cassandra Mercado, Sabin Abad

    • Ticket Status: Waiting on Compliance”

    • Comment:

      • Include an overview of the matter, actions taken, findings made, copies of any supporting documents, Engine job link, and request review/input by the Compliance

Info

Note: Ensure you frequently monitor the ticket for updates.

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Qualifiers for Compliance’s Involvment

QUALIFIERS

  • Claims of fraudulent and/or unlawful actions and activities (e.g., falsifying records, mischaracterization, nonregistered/unlicensed company/contractor)

  • Agreement violations

  • Customer privacy violations

  • False, unfair, or deceptive trade practices:

    • Statements that indicate systems are “free,” “at no cost,” or “$0”

    • Statements that consumer will no longer have a utility bill

    • Misrepresenting Federal Tax Credit eligibility

    • Statements that misrepresent details regarding the system or their financing agreement

    • Engaging in a sale with an individual whom, due to intellectual or linguistic challenges, would be unable to make informed decisions

    • Misrepresenting as the homeowner, or knowingly allowing an unauthorized party to conduct business on behalf of the homeowner

    • Allowing deceased, absent, or uninvolved parties to engage in an agreement

    • Falsifying permission-to-operate letters

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Note: A compliance issue is any violation or failure to adhere to laws, regulations, policies, or ethical standards that govern an organization's operations. The above list is not all-inclusive; if there is doubt on whether or not a matter requires Compliance’s involvement, please seek validation from Cassandra Mercado.