rron Hndrews T0:Emailing - (12072871339) 15:59 95/22/17 P9 1-8 Mr. Mitchell Tannenbaum: I Please find attached the requested answers to questions posed in your letter dated April 19, 2017 related to Ambit Energy? 5 marketing practices in the State of Maine. Please feel free to contact me should you have additional questions/concerns. Sincerely, Victor Quintana Sr. Manager, Regulatory Compliance, Ambit Energy 1801 N. Lamar Street, Suite 600 Dallas, Texas 75202 214.461.4725-Direct vquintana@ambitenergy.com :Sharron Hndreus T0:Eliiailili9 - (i287287i839) l6:58 85/22/17 GMT-84 P9 2?8 4 it: ?ne; Amarseneeoy Hill] North Slavic: Snin? Bill} 'l 2.32?? 2i [in?ll-T?? May 22, 2017 Mr. Mitchell Tannenbaum General Counsel State of Maine Public Utilities Commission 101 Second Street Halloweli, ME 04347 RE: Docket No. 2014?00184 Dear Mr. Tannenbaum: In response to your letter (attached) dated April 19, 2017, please find below our responses to the questions posed. in addition, we have included the documentation you requested regarding Ambit Energy?s marketing practices in the state of Maine: 0 Please explain what type of marketing practiceis) Ambit is using in Maine. Ambit Energy?s marketing practices are limited to word of mouth, peermto?peer and general informative meetings conducted by independent Consultants. is Ambit using its own employees for sales and marketing or is it using third?party companies? Ambit Energy uses independent Consultants. No third?party companies are in valved. - if third-party companies are doing work on behalf of Ambit, please provide the name of the companies. - - Please state what type of training is used to ensure that salespeople working on Ambit?s behalf are complying with all applicable laws and regulations. Please also provide any written training materials they are given, including any materials salespeople are provided with which to identify themselves as Ambit salespeople, including, for example, a picture identi?cation badge. - independent Consultants are required to pass testing specific to each market in which we operate. - Please provide what, if any, limitations Ambit places on the times of day when any type of sales call (telephone, door-to?door, or any other type) may be made. - No telephonic or door?to?door solicitation allowed. Please do not hesitate to contact me should you have additional question or concerns. Sincerely, Victor Quintana Sr. Manager, Regulatory Compliance (214) 461-4725 :Sharron Hndrews T0:Emaii illg - (12972871839) 16:59 35/22/17 GllT~04 Pg 3?8 STATE OF MAINE PUBUC Mark A. Vannoy Hany Lanphear DIRECTOR Carliste J. T. McLean R. Blues Williamson COMMSSIONERS April 19, 2017 Patricia Zacharie Corporate Counsel 8: Manager, Regulatory 8: Compliance Ambit Northeast, LLC 1801 North Lamar Street, Suite 600 Dallas, TX 75202 Via electronic CMS filing RE: Docket No. 2014-00184 Dear Ms. Zacharie: The Maine Pubiic Utilities Commission (Commission) is responsible for overseeing the retail electricity market in Maine and for monitoring the activities of any entity licensed as a competitive electricity provider (CEP). Ambit Northeast, LLC (Ambit) is licensed as a CEP in Mainel, and as such is subject to the regulatory oversight of the Commission. Thus, Ambit must adhere to, among other statutory and regulatory provisions, Chapter 305 of the Commission?s rules, Licensing Requirements, Annual Reporting, Enforcement and Consumer Protection Provisions for Competitive Electricity Providers. The Commission?s Consumer Assistance and Safety Division (CASD) has received complaints recently that indicate salespeople for Ambit may have violated the Commission's rules governing CEPs. in particular, our CASD staff has received complaints from proSpective customers alleging one or more Ambit salespersons failed to identify the company for whom the salesperson worked, made sales calls at unreasonable hours of the day, and gave false or misleading information regarding electricity rates and purported bene?ts for utilizing Ambit as a supplier. To evaluate whether these allegations warrant further Commission action, the Commission requests that Ambit answer the following: . Please explain what type of marketing practice(s) Ambit is using in Maine. . ls Ambit using its own employees for sales and marketing or is it using third-party companies? 1 Commission Order Granting License, Docket No. 2014-00184 (September 25, 2014). 101 Second Street, Haiiowcll, ME 043-17 - MAIL: l3 Suite Home Statitm, Augusta. ME 043334018 PHONE: (20712313831 1 FAX: (207} 2874039 :Sharron Hndrews T0:Email ing (i2372871l39) 16:58 85/22/17 Pg 4?3 Letter to Ms. Zacharie April 19, 2017 Page 2 a If third~party companies are doing work on behalf of Ambit, please provide the name of the companies. . Please state what type of training is used to ensure that salespeople working on Ambit?s behalf are complying with all applicable laws and regulations. Please also provide any written training materials they are given, including any materials salespeople are provided with which to identify themselves as Ambit salespeople, including, for example, a picture identi?cation badge. . Please provide what, if any, limitations Ambit places on the times of day when any type of sales call (telephone, door?to-door, or any other type) may be made. We appreCiate your attention to this matter. Please contact me if you would like to discuss any issue in this letter in advance of your written submission. We request that you provide the information in Docket 2014-00184 on or before May 5, 2017. Very truly yours, Mitchell Tannenbaum Mitchell Tannenbaum General Counsel :Sharron Hndrews To:Email ing - (12672871939) 16:58 95/22/17 P9 5-8 Ambit: Energy Privacy honey Ambit Energy uses appropriate commercially available anti? virus software to ensure that this Website does not contain or carry viruses. However, due to the rapidly developing nature OUR COMPANVWIDE PRIVACY COMMITMENT TO YOU As an internet user, we understand how important safeguarding your personal information is to you. At Ambit Energy Holdings (Ambit Energy). we are committed to protecting your personal information as you use our website. We would like to take this opportunity to let you know that Ambit Energy does not collect personally identifiable information from anyone unless such information is provided to us voluntarily and knowingly except as otherwise provided in this Policy. We only collect personal information for specific purposes, including providing you with retail energy service. We will not sell or make available your personal information to unaffiliated companies for commercial purposes unrelated to the business of Ambit Energy. However, we may use this information to inform you of goods or services that may interest you. Ambit Energy will not disclose any information about you to Unaffiliated companies or organizations without your consent except as disclosed to you in this Policy, unless: we are required to do so by law; we believe it necessary to respond to an inquiry or previde you with a requested service; It is necessary to make good on our Terms of Service Agreement we have entered into with you; or to protect the rights, property or personal safety of any other person, including another Ambit Energy customer or any member of the public, Ambit Energy and its affiliates recognize that by utilizing our website you are placing trust in us. We thank you. Let us assure you that we will take precautions to protect your information. in order to operate the Website and deliver retail electric service we may share your personal information with a service partner under strict conditions. We will not otherwise disclose your personal irformation to other companies without your explicit consant. You are not required to register or provide information to us in order to view a large majority of our site. However. to obtain services from Ambit Energy or to access portions of our Website, including, but not limited to, Ambit Energy?s ?Po-war Zone". "Customer togin" or other services provided by Ambit Energy, you may be asked to provide personal information. We use your information to personalize your Web experience or to provide you with requested services. Ambit Energy will only use y0ur information strictly in accordance with this Policy. HOW WE YOUR INFORMATION Ambit Energy will endeavor to take all steps deemed reasonable by Ambit Energy to keep secure any information We hold about you. Your information is stored on Secure servers that are protected in controlled We require our employees and data processors to respect the confidentiality of any personal information held by Ambit Energy. Ambit Energy takes many precautions, including administrative and technical measure, to protect your personal information against theft, mishandling and loss. Additionally, Ambit protects against misuse of your information, such as unauthorized access, disclosure, alteration. and destruction of your personal information. No one, including Ambit Energy, can give absolute assurance that your information will be secure 100% of the time due to the nature of the internet. Ambit Energy will not be held responsible for Events arising from unauthorized access to your personal information. of viruses and the Internet we strongly recommend that you employ similar anti~virus software when accessing the Ambit Energy Website. Ambit Energy makes no warranty that the Website or email correspondence is free from such viruses. CHILDREN Our Website contains educational energy-relaled information that may be of interest to children. Ambit Energy does not seek to gather personal intormation online from or about children under the age 0113. Ambit Energy encourages all children and young teens to ask their parents for authorization before providing any information about themselves or their household to anyone over the internal. DATA COLKECTION Ambit may use"cool .. sigh amine-I 1-3: I: Imam-.531: magma-I1": Irl 35v Iii.? :r -. aiiam" -- is, mic. thaii rm? ?EArs-jiurawz'i' -.: 55.1?? af?rm;- Ema-'52. 3C3. {min-Hr air-IN LC E1 .1. ,ziiztIz'I IFI- fag . IE {3:31 if; 15-: 3; .C min-g: if. 95.55211?. nugagnwm ujzzuI: --: 1:3 ma; {.5232 night if: I it: iI?: (?at-I55: {Si-7:63 a LIE ii'u? 23.55:} ism-35352169? :Sharron Hadreus T0:Emaii ing (12872871839) 18:58 85/22/17 Pg 8?8 As O. O. DIRECT SELLERS ASSOCIATION 1537 Street. NW i Suite HBO. Washington, DC 2000575605 202 11$? 8866 Fax 20? 452.90% deal org 3 consumer you should expect salespeople to: Tell you who they are, why they?re approaching you and what products they are selling. Promptiy end a demonstration or presentation at your request. Provide a receipt with a clearly stated cooling off period permitting the consumer to withdraw from a purchase order within a minimum of three days from the date of the purchase transaction and receive a fuil refund of the purchase price. Explain how to return a product or cancei an order. Provide you with promotional materials that contain the address and telephone number of the direct sailing company. Provide a written receipt that identifies the company and saiesperson, including contact information for either. Respect your privacy by calling at a time that is convenient for you. Safeguard your private information. Provide accurate and truthful information regarding the price. quaiity. quantity. performance, and availability of their product or service. Offer a written receipt in ianguage you can understand. Offer a compiete description of any warranty or guarantee. a salesperson, you should expect a USA member company to: Provide you with accurate information about the company?s compensation pian, products. and sales methods. Describe the relationship between you and the company in writing. Be accurate in any comparisons about products, services or opportunities Refrain from any uniawfui or unethical recruiting practice and exorbitant entrance or training fees. Ensure that you are not iust buying products soiely to qualify for downiine commissions. Ensure that any materiais marketed to you by others in the saiesforce are consistent with the company?s policies. are reasonably priced and have the same return policy as the company's. Require you to abide by the requirements of the Code of Ethics. Safeguard your private information. Provide adequate training to heip you operate ethicaliy. Base all actual and potentiai sales and earnings ciaims on documented facts. Encourage you to purchase only the inventory you can seli in a reasonable amount of time. Repurchase marketable inventory and sales aids you have purchased within the past 12 months at 90 percent or more of your original coat if you decide to ieave the business. Explain the repurchase option in writing. Have reasonable start~up fees and costs.