aimm has been successfully representing members’ interests to key regulators since 1995. aimm is at the forefront of regulatory change, ensuring that Members’ collaborative views on regulation are heard. aimm analyses every consultation released to check whether Member’s businesses could be affected and will then organise and deliver a response to the regulator, after member’s views and responses are collaborated. When a new consultation is released aimm will reach out to its members to call for feedback before delivering a considered and measured response.

  • 07/03/2018 PSA Consultation on Special Conditions for Society Lotteries
    When aimm and members introduced the potential for Society Lotteries to utilise a shortcode based call-to-action and mobile-bill payment for lottery tickets, we identified 5 Guidance documents, 2 Special Conditions requirements and one notice document that providers of Society Lotteries needed to be aware of as a result of introducing premium rate as well as the PSA Code of Practice. Society Lotteries are already heavily regulated by the Gambling Commission under the 2005 Gambling Act. To improve regularity simplicity, PSA and aimm collaborated on condensing some of the distributed PSA requirements into a single guidance document and to review the necessity of Special Conditions for  this product as the regulatory environment created by the Gambling Commission already protects consumers regardless of payment mechanism. PSA's proposal is that Special Conditions must exist and in addition they added excessive requirements to promotional material that go over and above the Gambling Commissions requirements for promotion. This will damage the simplicity of the shortcode based call-to-action that we already experience on television, radio and posters for charity donations and other products.  Certain key information needs to be available to consumers on promotions but PSA's proposals add clutter, causing rather than preventing  consumer confusion. We also believe that PSA has taken an overly cautionary line using experiences from affiliate promoted online competitions to push through additional conditions for Society Lotteries without a sufficient risk assessment that takes into consideration the predominantly  blue-chip brands that will promote their fundraising lotteries and raffles. aimm's final response is linked here. We welcome any member comments or queries on our response.
    Date Opened
    28th February 2018
    Deadline
    17th April 2018
  • 01/03/2018 Ofcom review of the 070 Personal Number Range
    070 numbers were originally designed to be used as a personal or ‘follow-me’ redirect type services with a higher than normal termination rate so that companies can fund the service and redirection costs on behalf of  the end user. Over the years, this range has been used to provide an increasing number of services, from hospital bedside phones to advertising response numbers and sophisticated personal assistant type services. As the calling party pays for the call to the 070 which on some networks can exceed £1 per minute and with the number being confused with a mobile number, Ofcom have reviewed the market and set our their proposals to regulate the termination fee. aimm believes that measures are required to improve pricing transparency for consumers and that high termination fee products (which determine the high consumer charges) could be moved over time to another range to provide number range transparency. There also has been fraud on this range taking advantage of the mobile-looking number. Ofcoms proposals however, in aimm's opinion would destroy the current range of services which are extensively  used by consumers and small businesses. We too often see regulatory actions chucking out both the baby and the bathwater, and we believe that Ofcom should have engaged with the 30+ companies providing 070 services to understand the range of services that are provided, a lot of which migrated to 070 after Ofcom's 2015 NGCS review resulted in a decimation of the 08 services market due to high Access Fees.   Some of the statistics used to bolster Ofcom's case are four years old and some are based on unverifiable data. We believe a national regulator should not use old data to examine issues as a lot of the historical issues have been resolved by improved industry standards. Our response lays out our members concerns and proposes alternative solutions that could easily be considered.
    Date Opened
    6 December 2017
    Deadline
    28th February 2018
  • 22/01/2018 PSA Consultation on Information required for Registration
    The Phone-paid Services Authority is consulting on changes to the registration requirements for companies using or facilitating a premium rate charging mechanism and for each premium rate service that is to go live on any mobile or fixed network. There are also changes to the categorisation of services (e.g. Competitions and Quizzes) that are designed to assist the annual market report. Registration of companies assists the value chain to perform due diligence on their contracted parties. Registration of products and services was always designed to help consumers reconcile their telecom bill information to the merchant's contact details to facilitate discussion about the bill entry. A side benefit is also to assist PSA with market monitoring and with enquiries into services that have caused complaints to them. aimm believes that a majority of the proposed changes to the registration information being requested do not assist consumers, are excessive and will present an additional regulatory burden to providers as well as introducing inaccuracies and potential regulatory action when service promotions do not match registration detail. PSA have not, in our opinion, sufficiently justified the proposed changes by demonstrating the linkage between the requirements that will cause a significant burden to companies and the regulatory efficiency and effectiveness that could be delivered. aimm has responded on behalf of members to ensure these points are made and to prevent regulatory changes that create unnecessary burden on industry.  
    Date Opened
    09/01/2018
    Deadline
    09/02/2018
  • 22/12/2017 PSA Business Plan and Budget 2018/19
    The Phone-paid Services Authority (PSA) has set out it's FY 2018-19 budget for consultation. The operational budget is £3,849,585, the same as the previous year but with an estimated market size reduction of £20.5m represents an increase to 0.94% of the cost of regulation to the companies operating in the market. PSA have kept the levy to the funding networks the same at 0.44% of outpayments by utilising fine revenue for the other 0.5% While the budget is a real-time reduction on previous years, aimm believes that there may be costs and manpower levels being sustained through roles that may no longer be applicable, the use of technology, particularly consumer facing is outdated and the sustaining of the position of being the "de-facto go-to party" for consumers for complaint resolution (which is not their role) is overdue a review as this drives regulatory changes that add constraint to innovation and new services.  aimm believes that PSA should be taking dramatic steps alongside industry to resolve the significant consumer support issues that exist instead of constraining how digital merchants conduct their business. aimm also believes that monitoring, compliance and regulation is being performed by too many parties, indicating an ineffective overall regulatory environment, duplicated costs and further constraints on business, which do not support innovation and new services. Our draft response is now available for member comments and we will require feedback by 22nd January to enable us to meet PSA's deadline of 26th January. Please download the document below, add your comments and return to regulatory@aimm.co
    Date Opened
    14th December 2017
    Deadline
    26th January 2018
  • 22/05/2017 Ofcom Call for Input on telecoms ADR scheme providers
    Alternative dispute resolution (ADR) is an important part of the protection available to consumers with complaints about their communications provider (CP). All communications providers are required to be members of an Ofcom-approved ADR scheme. Consumers can take their complaint to ADR eight weeks after they have complained to their telecom providers or, before that, if their complaint has reached deadlock. The two approved ADR schemes: Ombudsman Services: Communications (“OS”) and the Communications and Internet Services Adjudication Scheme (“CISAS”) are positioned effectively for communications issues, but are not able to provide ADR for users of premium rate services. Under the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015, premium rate merchants have to refer consumers to ADR in a deadlocked situation. Due to the telecoms linkage they must refer to the only two companies approved by Ofcom. These companies do not provide the correct support for either side of the dispute and in aimm's view it creates impasse. aimm has encouraged Ofcom to review this situation as part of its review of the two ADR providers.
    Date Opened
    31st March 2017
    Deadline
    12th May 2017
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