Topics and trends

Annual Report

August 1, 2023 – July 31, 2024

In 2023-24, we accepted 20,147 of the complaints from customers across Canada. This represents a 38% increase from last year and is the highest number of complaints accepted in our organization’s history.

20,147 accepted complaints in 2023-2024; 38% increase

Overview

Our teams worked hard to maintain efficient operations as we handled the increased volume of complaints this year. We maintained a resolution rate of 88%. 87% of complaints we resolved were settled within 20 days.

This year, we concluded 19,176 complaints containing 38,874* issues.

* A single complaint can contain more than one issue. For example, a customer may submit one complaint about both the billing of their internet service and roaming charges related to their wireless service. These would be reported as two issues.

87% of complaints resolved within 20 days

A complaint can contain multiple issues. 19,176 concluded complaints. 38,874 issues: number of complaints and issues that were accepted in 2023-2024.

Issues raised in complaints

  • Wireless issues remain the most-raised issue, accounting for 52% of all issues raised. Wireless issues increased by 27% this year.
  • Internet issues remain the second-most raised issue, accounting for 29% of all issues raised. Internet issues increased by 50%.
Table 6.1: Number of issues by service type, Year-over-Year (YoY) change

Note: Red text within tables shows an increase in issues compared to last year. Green text shows a decrease.

Issues by service type: TV 11%; Local phone 8%; Internet 29%; Wireless 52%; Other 0%

Figure 6.1: Five-year view of issues by service type

Spotlight on wireless services

  • Wireless remains the most complained-about service and represents 52% of all issues raised.
  • Wireless issues increased by 27% this year. There were more wireless issues raised this year than in any other year in the last five years.
  • Billing remains the top category of issues for wireless services with an increase of 39% from last year. Service delivery issues increased by 27%, and contract dispute issues increased by 12%. Table 6.2 shows the key issues that increased year-over-year and contributed to the overall rise in wireless complaints.
  • Primary contributors to the increase in wireless issues include:
    • incorrect charge for monthly price plan—31% increase
    • credit or refund not received—108% increase
    • regular price increase of monthly price plan—360% increase
Figure 6.2: Five-year view of wireless issues
Table 6.2: Top 10 wireless issues
Issue Number Proportion YoY (%)
Disclosure issues 2,952 15% +4%
Incorrect charge for monthly price plan 2,836 14% +31%
Credit or refund not received 2,120 11% +108%
Quality of service 1,458 7% +27%
Changes to the contract 1,043 5% +33%
Regular price increase of monthly price plans 772 4% +360%
Breach of contract 756 4% 0%
Third party credit reporting 721 4% +11%
Data charges 697 3% +70%
Repair issues and appointments 601 3% N/A
Figure 6.3: Five-year view of internet issues

 

Spotlight on internet service

  • Internet issues account for 29% of all issues raised by customers, up from 26% last year.
  • Internet issues increased by 50% this year.
  • Billing is now the top issue category for internet customers, with an increase of 84% from last year. Primary contributors to this spike in internet billing complaints include the following:
    • incorrect charge for monthly price plan—77% increase
    • regular price increase to monthly price plans—260% increase
    • credit or refund not received—107% increase
  • Service delivery issues raised by internet customers also increased by 27% year-over-year. Issues concerning quality of service remain the top issues within this category, continuing a five-year trend.
Table 6.3: Top 10 internet issues
Issue Number Proportion YoY (%)
Incorrect charge for monthly price plan 1,635 15% +77%
Disclosure issues 1,248 11% +63%
Quality of service 1,236 11% +4%
Credit or refund not received 992 9% +107%
Repair issues and appointments 707 6% N/A
Regular price increase of monthly price plans 622 6% +260%
Complete loss of service 608 5% +10%
Due dates not kept or delay for installation or cancellation of service 503 5% -19%
Termination fee 470 4% +73%
Unable to cancel 392 4% +55%

 

Spotlight on TV services

  • After complaints about TV services decreased for four years in a row, we saw an increase in issues about TV services. TV issues account for 11% of all issues, up 1% from last year.
  • The number of TV issues increased by 46% this year.
  • Notably, TV billing issues increased by 61% from last year. Customers raised more issues about incorrect charges for monthly price plans, credits or refunds not being received, and increases to monthly price plans.
  • Service delivery issues with TV services increased by 36%. Customers raised more issues about not being able to cancel services, quality of service and complete loss of services.
  • Issues with TV contracts increased by 43% this year. Disclosure issues account for 13% of all TV issues raised. Disclosure issues increased by 55% from last year.
Figure 6.4: Five-year view of TV issues
Table 6.4: Top 10 TV issues
Issue Number Proportion YoY (%)
Incorrect monthly price plan 677 16% +62%
Disclosure issues 537 13% +55%
Quality of service 427 10% +9%
Credit or refund not received 349 8% +108%
Repair issues and appointments 275 6% N/A
Regular price increase of monthly price plans 228 5% +165%
Complete loss of service 222 5% +28%
Changes to the contract
188 4% +25%
Due dates not kept or delay for installation or cancellation of service 160 4% -24%
Unable to cancel 155 4% +67%

 

Figure 6.5: Five-year view of local phone issues

Spotlight on phone services

  • Local phone services account for 8% of all issues, down from 9% last year.
  • Issues raised about local phone services increased by 24% this year.
  • Billing issues increased by 51% for phone services. Customers raised more of the following issues:
    • incorrect charges for monthly price plans — 48% increase
    • credit or refund not received — 67% increase
    • regular price increase of monthly price plan —147% increase
Table 6.5: Top 10 local phone issues
Issue Number Proportion YoY (%)
Incorrect charge for monthly price plan 464 15% +48%
Disclosure issues 336 11% +35%
Complete loss of service 284 9% +23%
Quality of service 247 8% -18%
Credit or refund not received 190 6% +67%
Repair issues and appointments 182 6% N/A
Regular price increase of monthly price plans 180 6% +147%
Unable to port 144 5% -1%
Due dates not kept or delay for installation or cancellation of service 118 4% -34%
Termination fee 113 4% -1%
Unable to cancel 113 4% +64%

 

Breakdown of issues across all service types

For the first time in the last five years, customers raised most often the issue of incorrect charge for monthly price plan. Disclosure issues are now the second-most raised issue across all service types. Notable year-over-year increases across all service types include the following:

  • regular price increase of monthly price plans — 261% increase
  • credit or refund not received — 106% increase
  • incorrect charge for monthly price plan — 47% increase
Table 6.6: Top 10 issues across all service types

Billing issues

Billing issues include several concerns such as:

  • incorrect charge for the monthly price plan
  • unexpected price increases to the monthly price plan
  • promised credits or refunds that are not received 
  • disputes about other charges such as roaming, data usage, cancellation or equipment charges.

Service providers are expected to abide by the applicable codes set out by the Canadian Radio-television and Telecommunications Commission (CRTC) as well as their own terms of service and agreements with customers.

Billing is now the top issue category. 52% increase from last year.

Figure 6.6: Five-year view of billing issues

 

Following a decline in billing issues since 2019, we saw a significant 52% increase in billing issues in 2023-24, nearly returning to 2019 levels. This resurgence of billing issues comes at a time when people in Canada face increasing prices for goods and services. This may help explain why people are more concerned about billing discrepancies.

This year, billing issues account for 45% of all issues raised, up from 39% last year. This increase was consistent across all service types:

  • Wireless billing issues — 39% increase
  • Internet billing issues — 84% increase
  • TV billing issues — 61% increase
  • Local phone billing issues — 51% increase
Figure 6.7: Billing issues by service type
Table 6.7: Billing issues – Top 10 service providers

* The average billing resolution rate was 89%.

 

Table 6.8: Top 10 billing issues
Issue Number
Incorrect charge for monthly price plan 5,675
Credit or refund not received 3,670
Regular price increase of monthly price plans 1,817
Equipment charges 829
Deactivation charges or billed after cancellation 758
Data charges 697
Misapplied payments 593
Roaming charges 582
Invoices not received 569
Installation, activation, or reactivation charges 513

Incorrect charge for monthly price plan

In 2023-24, 33% of all billing issues were about customers being charged incorrectly for their monthly service plan. This issue occurs when the customer is charged a different amount than they believe they agreed to.

Continuing a four-year increase, complaints about incorrect charge for monthly price plan increased by 47% from last year.

Incorrect charge for monthly price plan is the leading billing issue. 5,637 times raised; 15% of all issues across all services; An increase of 47% from last year.

Figure 6.8: Incorrect charge for monthly price plan by service type
Table 6.9: Incorrect charge for monthly price plan – Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 1,690 30%
TELUS 1,010 18%
Bell 987 17%

Key message

When we investigate complaints about the incorrect charge of a monthly price plan, we review the rate the customer agreed to and see if it matches the billed rate. If the two rates are different, we ask the service provider to explain why that is. To ensure that the provider is acting reasonably, we also try to understand why the provider believes it has the right to bill a different rate.

Billing issues often arise when information is not clear. As a result, the customer may be confused. Their expectations may not be met, or they may suspect that the provider is charging them incorrectly. We encourage customers to read their agreements carefully. Agreements typically set out what the customer will be billed. If the customer has a fixed-term agreement, the provider may be required to notify the customer before the end of the commitment period about the monthly price going forward.

Regular price increase of monthly price plan

Customers often complain that their service provider increased the price of their monthly service plan. This issue increased by 261% this year. It occurred across all service types:

  • Wireless regular price increase of monthly price plan — 360% increase
  • Internet regular price increase of monthly price plan — 260% increase
  • TV regular price increase of monthly price plan —165% increase
  • Local phone regular price increase of monthly price plan — 147% increase

Issues about regular price increases of monthly price plans make up 5% of all issues raised, and 11% of all billing issues.

 

Figure 6.9: Issues with the regular price increase of monthly price plans by service type
Table 6.10: Issues with regular price increase of monthly price plans – Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 487 27%
Bell 390 21%
TELUS 224 12%

Key message: increases to monthly price plans

Service providers may adjust prices for future months if the CRTC consumer protection codes and their contracts permit them to do so. As the cost of living rises and household budgets tighten, customers may be more sensitive to these adjustments. Our role is to ensure that service providers follow the terms set out in their contracts and that they abide by applicable CRTC codes when changing any prices.

When reviewing these cases, we first look at whether a provider is permitted to change the price. For example, the CRTC Wireless and Internet Codes do not permit providers to change the monthly price during a fixed-term agreement. Providers may change the price for month-to-month (no commitment) services with at least 30 days’ notice and a clear explanation of the change. If the provider is permitted to change the monthly price for services, we then verify that the provider met the requirements of their contract to increase the price. For example, did the provider notify the customer and did they give the customer the required information about the change? Understanding their contracts and the CRTC codes help customers know their rights and what to look for when addressing price increases on their bills.

Credit or refund not received

For the second year in a row, concerns about not receiving a promised credit or refund were the second biggest billing issue.

This issue accounts for 21% of all billing issues, up from 16% last year. The number of times the customers raised issues about a credit or refund not being received increased 106% year over year.

For the second year in a row, credit or refund not received is the second highest billing-related issue. 106% year-over-year increase; 21% of all billing issues; 3,670 times raised.

Figure 6.10: Issues with credits or refunds not received by service type 
Table 6.11: Issues with credits or refunds not received – Top 3 service providers 
Service provider Number of times issue was raised Proportion of issue
Rogers 984 27%
Bell 626 17%
TELUS 493 13%

Key message: credit or refund not received

When we investigate complaints about a credit or refund not being received, we try to find out if the provider owes the customer a credit or refund. We ask customers to tell us about when they believe they were offered a credit or refund. If the provider owes a credit or refund, we ask the provider to show that it has been provided. If it hasn’t, the provider must explain why they withheld it. We ask providers to thoroughly review their own records of customer interactions about unfulfilled credits or refunds to help resolve the issue more efficiently.

To reduce complaints about this issue, we strongly encourage providers to consider whether their billing systems and customer service procedures adequately ensure swift actioning of promised customer credits or refunds.

Contract dispute issues

Contract dispute issues include problems related to misunderstandings or conflicts over the terms set out in customer agreements. Common concerns include the following:

  • Disclosure of contract terms is unclear
  • The service provider breached the terms of the contract
  • The service provider changed the contract
  • The customer encountered problems when trying to renew their contract

These disputes often arise when the service provider and the customer disagree about one or both of these things:

  • the terms of the contract
  • whether the provider performed its contractual obligations to the customer

The number of contract dispute issues increased by 21% this year.

Disclosure issues

Disclosure issues are the most-raised contract dispute problem. Customers often raise concerns about a lack of information or information that is unclear. This is reflected in the data, as disclosure issues continue to be a top issue. Customers raised 5,116 disclosure issues across all service types this year— a 21% increase from last year. This is the first time this issue has increased in five years.

Disclosure issues account for 13% of all issues raised across all service types.

Figure 6.11: Five-year view of disclosure issues

 

Disclosure issues by type of service

Lack of clear disclosure remains the top issue raised by wireless customers and is now the second most common issue raised by customers of internet, TV, and phone services. Customers raised 21% more disclosure issues overall. Internet customers raised 63% more disclosure issues. TV customers raised 55% more disclosure issues and local phone customers raised 35% more disclosure issues.

Figure 6.12: Disclosure issues by type of service

 

Table 6.12: Disclosure issues – Top 10 service providers

* The average disclosure resolution rate was 90%.

 

Table 6.13: Types of disclosure issues broken down by service type

No consent or contract conflicts with agreement

Of all the concerns customers raise about disclosure, 88% are the result of a disagreement between the customer and the services provider over one or both of these issues:

  • whether the customer consented to the agreement
  • a mismatch between what the customer believes they agreed to purchase versus what the contract sent to them after the transaction occurred shows

Issues raised about no consent or contract conflicts with agreement increased by 35% across all service types.

Figure 6.13: Issues where there is no consent or contract conflicts with agreement by type of service
Table 6.14: Disclosure – No consent or contract conflicts with agreement: Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 1,469 33%
Bell 743 17%
TELUS 740 17%

Device financing plans

In March 2021, the CRTC issued a decision determining that device financing plans fall under the scope of the Wireless Code. The CRTC found that requiring customers to pay the balance of a device financing plan constitutes an early cancellation fee. To inform future reviews of the Wireless Code, the CRTC asked us to track complaints related to device financing plans in our Annual and Mid-Year Reports.

Issues with device financing plans increased by 38% this year. This issue was raised 328 times with a large portion of customer concerns about disclosure.

Table 6.15: Disclosure – Rules related to agreement are unclear: Top 3 service providers
Service provider Number of issues Proportion of issue
Rogers 122 25%
Bell 68 14%
Fido 57 12%
Table 6.16: Issues with device financing plans for wireless services

*The resolution rate for all issues was 87.8%

Key message: device financing plans

Service providers offer device financing plans to help lower the cost of mobile devices for customers. These financing plans typically spread the device cost into monthly installments over a fixed term or defer some of the upfront cost of the device until the end of the term. Each year, we track and monitor issues about device financing plans, as requested by the CRTC.

While device financing plans are permitted under the Wireless Code, these agreements have become increasingly complex. Some include a monthly device subsidy, and some offer device discounts or device bonuses. The financing may also be provided through a third party, not the wireless service provider itself.

Some providers offer device return options. For example, a customer may have to return the device at the end of their contract or pay an amount to keep it. Customers who don’t know that they must return their device or follow certain conditions to return their device may be surprised by device charges at the end of the contract, particularly if they cancel their contract early.

Given the complexity of device financing plans, we recommend that service providers simplify the way they explain these options to customers. Providers should also ensure their representatives are trained to accurately explain end-of-contract requirements and how early cancellation fees are calculated. Service providers should be very clear about any device return conditions during the sales transaction. These should be clearly and prominently set out in customer contracts. The provider should also inform their customers if a third party is involved in the device financing.

Before entering into an agreement with a device financing plan, we encourage customers to ask service providers what happens to their device financing if they change their wireless services or cancel early. Customers can avoid surprises by asking for an example of how the provider calculates early cancellation fees. Customers should also carefully review their device financing plan agreements to understand three key things:

  1. how the plans works
  2. who they are contracting with for financing (e.g. their wireless provider or a third-party financing company)
  3. if they are agreeing to return their device to the provider at the end of the commitment period.

Changes to the contract

Changes to the contract issues arise when:

  • a service provider notifies the customer of a change to the terms of their agreement; and,
  • the customer does not believe the provider is allowed to make the change.

        or

  • The provider fails to notify the customer about a change to the terms of their agreement when required.

Issues about changes to the contract account for 4% of all issues raised. This year, the issue increased by 28%.

Figure 6.14: Changes to the contract issues by type of service
Table 6.17: Changes to the contract issues – Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 499 29%
Bell 228 13%
Public Mobile 228 13%

Key message: changes to the Contract

The total amount a customer pays for their telecommunications and television services often has several parts: the regular monthly price plan, fees for optional add-on services, and equipment rental fees or device subsidy fees. In addition, providers may offer promotional discounts or a loyalty program that allows customers to apply rewards as credits towards their service costs.

The CRTC consumer protection codes have rules about what contract terms providers may or may not change. For example, the Wireless Code requires providers to obtain a customer’s express consent before changing any “key contract term,” such as the minimum monthly charge during the commitment period. Providers may not change the minimum monthly charge during a fixed-term agreement without customer consent. For prepaid or month-to-month arrangements, providers may change key terms, such as the monthly price, but they must give at least 30 days’ notice and a clear explanation of the change.

Providers are typically allowed to change other (non-key) contract terms without the customer’s consent. They must, however, give at least 30 days’ notice and clearly explain the changes before any increase takes place. Non-key contract terms may include changes to monthly discounts and loyalty programs. Customers should be aware that providers may have the right to change parts of the contract that may affect the overall cost. During sales transactions, customers should make sure they clearly understand which parts of the price are guaranteed for a set period and which may change without notice.

When there is a dispute about changes to a contract, we ask the provider to show the terms that the customer agreed to and explain the changes it made. If the provider changed the contract, it must also show that it had the right to do so. We verify whether the relevant CRTC codes allow the provider to change those terms. We also check if the provider followed the necessary steps to make the change. For example, did it notify the customer in advance as required? Did it get the customer’s express consent if the terms of the agreement or a CRTC code require it?

Service delivery issues

Service delivery issues are problems with the quality, reliability and management of a customer’s service. These issues, which account for 28% of all issues raised in 2023-24, include the following:

  • slower than expected broadband or wireless speeds (e.g., intermittent service)
  • complete loss of service
  • delays to install or cancel services
  • difficulties cancelling or porting services

Service delivery issues increased by 26% across all service types.

Figure 6.15: Five-year view of service delivery issues

 

Figure 6.16: Service delivery issues by service type

 

Table 6.18: Top 10 service delivery issues
Issue Number
Quality of service 3,382
Repair issues and appointments 1,775
Complete loss of service 1,634
Due dates not kept or delayed for installation or cancellation of service 1,085
Unable to cancel 1,036
Unable to port 640
Nonpayment or collections 455
Installation error 446
Out of service due to policy 208
Seasonal suspension 92

“I am very grateful to CCTS, as my service provider owed me over $600 in overcharges. Thank you for your intervention. I was thoroughly pleased with the application process, the transparent emails, and the service provided by CCTS.”

Customer who used the CCTS’ services

Quality of service

Customers raise quality of service issues when their telecommunications or television services do not work to the level that they expect. These are some common examples:

  • slower than expected internet or wireless data speeds
  • service works on and off with regular or irregular interruptions
  • poor sound quality such as static or clips on their wireless or landline service
  • disconnected (dropped) calls

Quality of service issues account for 31% of all service delivery issues, an increase of 12% from last year. This year, 43% of quality of service issues were raised by wireless customers, and 36% by internet customers.

Figure 6.17: Quality of service issues by service type
Table 6.19: Quality of service issues – Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 748 22%
Bell 667 20%
TELUS 512 15%

Key message: quality of service issues

Quality of service issues, such as slower-than-expected internet speeds or intermittent services, frustrate customers. Customers rely on their connectivity services to work, learn, stay connected with family and friends and to access content to keep them informed and entertained.

When we look at complaints about quality of service issues, we determine the service quality the customer ought to have, for example, from the service provider’s service level commitment or the customer’s contract. We also look at the evidence submitted by both the customer and the service provider that shows the service level the customer actually received. If the customer does not experience the service quality they expect, we:

  • examine whether the service provider followed its usual troubleshooting process to correct the service quality or if it issued credits to the customer
  • consider other steps the provider has taken to fix the issue and resolve the complaint
  • consider what is fair and reasonable in the circumstances. For example, there may be a better plan for the customer given the actual experience that the provider is able to deliver.

While the CCTS cannot fix broader infrastructure or network issues, we can hold service providers accountable for delivering what has been agreed to. If the customer does not receive the service levels they ought to experience, we expect the provider to either correct the problem or compensate the customer in some other way.

Where a customer in a fixed-term agreement does not receive the quality of service they expect and the provider states that the issues are due to an infrastructure or network issue, we may consider other appropriate remedies. For example, we will determine whether it is fair and reasonable for the customer to pay an early cancellation penalty for a service that is not working as intended or whether the customer should receive compensation for the inconvenience.

Where customers have agreed to a fixed-term contract for wireless or internet services, we encourage them to take advantage of the 15-day trial period that is required under the Wireless and Internet Codes. The required trial period lets customers find out if all aspects of the service perform to their expectations. If the service does not meet expectations, customers should contact their provider during the 15-day trial period to discuss options or cancel their service without penalty.

We also encourage providers to give clear and accurate information to customers about internet services. This information should include things like expected service quality during peak periods and typical download and upload speeds. This information can help customers make more informed decisions. It lets them compare their personal expectations to the service quality the provider has told them to expect. This, in turn, can reduce confusion and frustration.

The CRTC plans to hold a public consultation on standardized information for internet services to help consumers easily compare plans, like labels about price and download speeds.

Issue spotlight: Increased customer challenges with cancelling or switching services and cancellation fees

This year, customers raised more issues with cancelling their service or transferring (porting) their services to another provider. Customers also raised more concerns about cancellation fees. There were considerable increases in these issues across various service types.

  • Termination fee issues increased by 35% from last year. This year, internet customers raised 42% of the cancellation issues and wireless customers raised 36%.
  • Unable to cancel issues increased by 47% this year, after a 31% jump last year.
  • Issues where customers could not transfer (port) their service increased by 25%, after a 23% increase last year.

We will continue to monitor these issues as one of the primary objectives of the CRTC’s consumer codes is for customers to be able to more easily switch providers in a dynamic marketplace.

Key message: cancelling or switching services

Customers have the right to cancel their phone, wireless, internet or TV services. They do not need to notify their provider in advance. After a provider gets a cancellation request from a customer, it must cancel the service right away, unless the customer asks that the service be cancelled at a later date. To transfer services to a new provider, customers should ask their new provider to do so on their behalf.

If customers want to change their phone, wireless, internet or TV services, the process should be easy. Billing should stop as soon as the customer cancels services. Transferring or cancelling service does not relieve the customer of their responsibility to make sure that their account is fully paid. For example, if the customer cancels a fixed-term agreement before the end of the commitment period, they may need to pay cancellation fees. The contract should clearly state the early cancellation fees that apply and how they will be calculated.

Where a customer complains about being unable to cancel or transfer services, we ask the provider to demonstrate that it followed the regulatory requirements and its processes to honour the customer’s cancellation or transfer request. When raised in the dispute, we will also find out if billing continued after processing the customer’s cancellation request and verify if any cancellation fees were calculated and applied as set out in the agreement. If we find that a provider made an error in the cancellation fee or did not stop billing after the cancellation, we will require the provider to refund these charges to the customer.

Credit management issues

Credit management issues account for 4% of all issues. About 90% of these are related to third-party credit reporting. A customer may complain that the service provider has improperly reported their account to a collection agency or credit bureau. These are often disputes over how the provider handled the customer’s credit information and how it affected their credit history. Credit management also includes issues about credit deposits or limits. These include security deposit requirements, amounts, refunds, and interest.

Third party credit reporting

The number of credit reporting issues increased from last year by 17%, after a 16% decrease noted in last year’s Annual Report. Wireless customers account for 59% of all credit reporting issues, followed by internet (27%), TV (9%) and local phone services (5%).

Figure 6.18: Third party credit reporting issues by service type
Table 6.20: Third party credit reporting – Top 3 service providers
Service provider Number of times issue was raised Proportion of issue
Rogers 389 32%
TELUS 203 17%
Bell 190 15%

Key message: third party credit reporting

When there is a dispute about credit reporting, the service provider must demonstrate that it had the authority to make a credit report. We assess whether the circumstances for making the credit report were valid. For example, did the customer fail to pay for the services by the due date? We also check to make sure the provider followed its own internal credit reporting procedures. For example, did it take the appropriate steps to report to the credit bureau? Was the reporting accurate?

If we find that the provider did not have a valid reason to report, we will require it to demonstrate that it has corrected the credit report. We will also consider whether the provider should compensate the customer for any proven loss, damage, or inconvenience arising directly from the unjustified credit reporting.