Comreg Draft code of practice for PRS final call for responses

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I know a lot of people on here have had problems with premium rate numbers (particularly with subscribing and unsubscribing). Well comreg have been looking at reforming the rules governing the sector and published a draft code of practice back in Dec 2010. They're now looking for more submission and responses to the draft document and have extended the deadline for submissions to September 16th 2011. I know a lot of people dont think comreg are very good but nows the time to submit your thoughts on the proposed new regulations.

The draft code of practice is here:
http://www.comreg.ie/_fileupload/publications/ComReg_1092a.pdf

and the responses received to date are here:
http://www.comreg.ie/_fileupload/publications/ComReg1151.pdf

Following requests received from interested parties, the Commission for communications Regulation (“ComReg”) has today extended the deadline for the submission of responses to its current public consultation on the revised draft Code of Practice to be followed by Premium Rate Services providers to 4:00 pm on Friday, 16 September 2011.

Some of the proposals in the draft code of practice:

It's a lot to read but foremost in the proposed measures was the “double opt-in” requirements which would require consumers to positively confirm, by sending an SMS, of their intention to subscribe to a service. Many PRS companies are opposing this as excessive.

Vodafone and Ericsson IPX submitted that the decline in end-users contacting their customer care lines indicates an improvement in pricing transparency and improved customer care.

Realm, Tacutext, mBlox and the IPPSA made reference to the UK where
it was claimed that “double opt-in” is required only for Subscription Services in excess of £4.50 per week and not to subscriptions that cost less,

Page 33 of the responses document.

Comreg is still fully backing the Double opt in system thankfully

Q. 13. Do you agree with the proposal to require end-users to provide positive
confirmation of their desire to continue in a Subscription Service after a certain expenditure level? If not, please provide reasons to support your
view.
Summary of Respondents’ Views
Modeva opposed the proposals and considered the specific message wording
and the requirement for PRS providers to keep a running total of all costs
incurred in the past by consumers to be disproportionate to the issues raised
and an undue burden on the PRS providers.
Similarly, H3GI, Bluestream, Tacutext, Vodafone, Eircom, Ericsson IPX and
Telecom Express disagreed with the proposal with most citing the requirement
to clearly inform the consumer, both at the time of sign-up, and periodically, of the costs and how to exit the service if the end-user should so wish

And comregs response:

ComReg’s Position
ComReg‟s primary objective is to ensure that end-users of PRS are, at all times, aware of and in control of their interactions with PRS particularly in so far as the interactions incur costs for end-users. However, having considered the submissions and considering the inclusion of enhanced provisions relating to promotions and with the introduction of positive confirmation (“double optin”) to initiate a subscription, it is not considered necessary to introduce a requirement that end-users reconfirm their intention to continue with the PRS, at this time.

Anyway there just two issues I picked out from the 73 page document. If you feel strongly about these PRS companies then have a gander and make a submission in support or against something you see. The more people responding to it the better as you can bet the PRS companies are hounding comreg on this with talk of the end of the PRS business if these measures get through (Not true as comreg have shown examples of other countries like Sweden introducing double opt in measures and no serious decline for the PRS industry).