Section 6.9.1 of the Revised Long-Term Plan published by the IPA on April 20, 2020 describes a new requirement for Approved Vendor Designees (i.e., third-party entities working with Approved Vendors that have direct interaction with end-use customers) to register and be listed on the ABP and Illinois Shines websites along with the Approved Vendors with which they’re working. The purpose of this new requirement is to increase transparency for the Program. Potential customers will be able to verify that a company that reaches out to them is actually a Program participant registered with the Program (and likewise will be able to review if they are listed in the Program’s consumer complaint database or the disciplinary actions report). All Designees will be added to the Program’s publicly facing Designee database once registered. This database will be housed on both the ABP and Illinois Shines websites. The Program Administrator plans to release the functionality in the ABP portal that facilitates compliance with this requirement on Monday, October 26, 2020.
New Designees must register prior to working with any Approved Vendor. Existing designees of an Approved Vendor must register by Thursday, December 10, 2020 (which is 45 calendar days from the October 26, 2020 release of the Designee Registration functionality) to remain in compliance with Program requirements.
Once this functionality becomes available, all third-party entities that have direct interaction with end-use customers of the ABP and that operate within the Illinois Adjustable Block Program need to register as Designees on the Program website. Once registered, these entities can indicate in the portal one or more of the following Designee roles:
- Disclosure Form Designee – An entity that is permitted to generate Disclosure Forms on behalf of an Approved Vendor.
- Community Solar Subscriber Agent Designee – An entity that is permitted to manage the community solar subscription information for an Approved Vendor’s community solar projects.
- Marketing or Sales Designee – An entity that is designated to act as a marketing agent and/or customer acquisition agent on behalf of an Approved Vendor or Designee. This includes, among others, entities that engage in solicitations through any channel (in-person, telephone, etc.), as well as entities that perform online lead generation services.
- Installer Designee – An entity that has been designated to install systems on behalf of an Approved Vendor or Designee.
The IPA and Program Administrator reserve the right to add or remove roles as needed over time. Approved Vendors and Designees can add and remove Designees within their portal as needed. All registered Designees are only authorized to act in that designated role with Approved Vendors or Designees that have accepted it as a Designee and have not revoked that acceptance.
Failure by a Designee to comply with applicable Program requirements could subject the Designee to suspension or termination from registration. If the Designee ignores a suspension or termination decision made by the Program Administrator or the IPA and continues its market activity nonetheless, any Approved Vendor or Designee that works with the Designee during that period may be subject to discipline. Likewise, Approved Vendors and Designees found to be working with entities that fail to register as Designees with the Program may be subject to discipline.
Approved Vendors are responsible for ensuring that both their Designees and Designees of their Designees register with the Program. Approved Vendors who fail to do so may be subject to disciplinary action. For example, if an Approved Vendor has an installer as a Designee, and that installer hires a lead generation firm to assist with marketing, the Approved Vendor is responsible for ensuring that the lead generation firm (in addition to the installer) registers with the Program. One benefit to Approved Vendors through this system is that they will know which downstream firms are working with their direct Designees and may be able to better monitor those firms’ behavior, as the Approved Vendor ultimately is responsible that each of the entities under its umbrella complies with Program requirements.
A webinar to introduce the Designee registration functionality and provide training on how to use it has been scheduled for today October 23, 2020 at 1 PM Central Prevailing Time to ensure that all entities are prepared to utilize the functionality before it goes live. Approved Vendors and Designees may register for the webinar via the following link: https://us02web.zoom.us/meeting/register/tZYofu2oqjkvGtHYwGVr0wQku6H-4O1QsydL. If you are not able to attend this training webinar, it will be recorded and posted to the ABP website for easy access and review.
Please reach out to the Program Administrator at [email protected] or (877) 783-1820 with any questions.