Category Archives: Criticising the Code

Peter Moon writes about TCP Code in the AFR

Posted on 11 September 2012 by Peter Moon

Cooper Mills telco lawyer Peter Moon has today devoted his weekly Australian Financial Review column to a status report on the 2012 TCP Code, now that it is in force. What struck us was how pro-active some providers are being, … Continue reading →

Posted in Backgrounders, Criticising the Code | Leave a comment

Dumbbell drafting: Clauses 7.12.1 and 7.12.2 not fit for purpose

Posted on 7 September 2012 by Peter Moon

It’s stunning, but two whole clauses of the TCP Code have no effect.  They are supposed to be the detailed rules that apply if a service provider changes its upstream wholesale arrangements.  But thanks to the worst piece of regulatory … Continue reading →

Posted in Criticising the Code, Customer Transfers | Tagged | Leave a comment

Telcos now need customer consent to sell their business

Posted on 6 September 2012 by Peter Moon

TCPCode.com.au really doesn’t set out to find fault with the drafting of the new Telecommunications Consumer Protections Code. We just study it very carefully so we can help telcos comply. We can’t help it that careful reading reveals a lot … Continue reading →

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At $6,275 per word, we deserved better

Posted on 4 September 2012 by Peter Moon

Based on estimates in the Federal Government’s Regulatory Impact Statement on the 2012 TCP Code, the average cost of implementing a single word of the 2012 TCP Code, during set up and Year 1 of operation, will be $6,275. At … Continue reading →

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Was anyone awake?

Posted on 3 September 2012 by Peter Moon

Was anybody awake when the 2012 TCP Code was drafted?  It may seem an unkind question, but if the cap fits… Today, Cooper Mills started to prepare our expert checklist for Chapter 5 of the Telecommunications Consumer Protections Code — … Continue reading →

Posted in Billing, Criticising the Code | Tagged , , , | Leave a comment

Industry to TCP regulators: We need a direction

Posted on 22 August 2012 by Peter Moon

Possibly the top two objectives of the 2012 TCP Code  are (a) to reduce the number of customer complaints, and (b) to get any complaints that do arise closed fast.  Which makes it pretty remarkable that the Code stumbles over … Continue reading →

Posted in Complaint Handling, Criticising the Code | Leave a comment

Bizarre TCP Code rule: Telcos must make customers pay!

Posted on 10 August 2012 by Peter Moon

It’s true … The TCP Code contains a few bonkers things, but nothing more weird than the clause that requires telcos to take action against their customers even if they don’t want to. You might have thought that a set … Continue reading →

Posted in Credit & Debt Management, Criticising the Code | Leave a comment

TCP Code fails its own clarity test

Posted on 11 July 2012 by Peter Moon

Since 1996, Cooper Mills lawyer Peter Moon has written a weekly technology column in the Australian Financial Review.  Being something of a stickler for clear english expression, Peter isn’t impressed at the Code’s overly complex language and layout.  Read Peter’s … Continue reading →

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