Recommendation Regarding Consumer Broadband Labels

The FCC Consumer Advisory Committee (CAC) was asked to build on the CAC’s extensive work in 2015/2016 on consumer broadband disclosures and develop recommendations on how the Federal Communications Commission should define “Point of Sale” for purposes of the label requirement and does the type or form of disclosure vary depending upon the nature of the consumer’s interaction with the service provider, e.g., in-store face-to-face with a sales representative, over the phone, on the web, at kiosks, etc. The CAC was also asked to consider how introductory rates impact a consumer’s decision to purchase broadband service and how should that inform the label’s display of such rates. The CAC recommends:

  1. The FCC should define Point of Sale as the shopping period beginning at the time the consumer seeks to determine the best broadband product for their needs and including the point at which the consumer makes the purchase. The Point of Sale occurs online and through alternate sales channels (e.g., company retail location, reseller location, or over the phone). The label shall be available at each Point of Sale.
  2. The required disclosure of the label is satisfied on a provider's website and at the alternate sales channel.
  3. The required disclosure must be effectively communicated in a manner that complies with applicable accessibility requirements, including Web Content Accessibility Guidelines, 2.1, Level AA, when conveyed electronically.
  4. The FCC should consider allowing smaller providers additional time to comply with the requirements.
  5. The FCC require that the month-to-month rate for stand-alone broadband service be displayed on the Consumer Broadband Label. If applicable, available promotional or discounted rates and their duration shall be provided via a link or noted on the label, so long as the month-to-month rate is listed conspicuously as the price of the service.

Recommendation Regarding Consumer Broadband Labels