DP18/9 response form

We are asking for comments on this interim report by 31 January 2019.

Please use this online form or alternatively email: [email protected]

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Q1: Do you agree with our six evidential questions to help assess concerns about fairness of individual price discrimination cases? Are there any other questions that are as, or more, important than the ones listed? If so, what are they?

Q2: Where consumers who shop around get good deals but those inert ones not shopping around do not, what factors should determine whether this trade-off is fair? In particular, to what extent are the following factors relevant:

Q2a: The scale of the price differential between consumers?

Q2b: The characteristics of the consumers who are affected? In particular, is it only unfair when it is vulnerable consumers who lose out, or is it also unfair when non-vulnerable customers lose out? Can it also be unfair even when the vulnerable benefit?

Q2c: The reasons why existing consumers do not switch to a better deal?

Q2d: The transparency of firms’ pricing practices?

Q3: To what extent is it appropriate for firms to target and tailor their pricing approach to consumers who are not likely to respond to future price rises? Does the answer depend on the techniques that firms use to achieve this (eg through predictive modelling, product design, communication with the consumer)? Please provide reasons to support your answer.

Please provide reasons to support your answer.

Q4:

Q4: What should we expect firms to do to help reduce the cost to consumers of shopping around and, if necessary, switching to another provider, in particular with respect to:

Q4a: helping consumers understand their choices

Q4b: the amount of effort required to make their choice

Q4c: not discouraging switching or shopping around

Q4d: being transparent about pricing and what factors are used to determine pricing

Please provide reasons to support your answer.

Q5:

Q5: What should longstanding consumers be able to expect of their provider when they become inactive in that particular market? In particular what should be expected of:

Q5a: the support the provider gives their customers to ensure they are making informed product choices?

Q5b: the default outcome in the event of prolonged inactivity (eg contract renewal, contract termination, or automatic switching to a different product)?

Q5c: the maximum price differential they are paying relative to the best available rate for that provider?

Please provide reasons to support your answer.

Q6:

Q6: On the discussion on potential remedies in this paper:

Q6a: Do you agree with the types of remedies that we have set out? If not, please explain which type of remedy you disagree with and why.

Q6b: Are there other types of remedies that we should consider that do not fit into these categories? If so please explain them and what adverse effect you think they would remedy, mitigate or prevent.

Q6c: Are there particular examples from other sectors, or other countries, that you think we should consider to inform our approach? If so, please provide detail and references where possible.

First published: 31/10/2018 Last updated: 31/10/2018