Everyone benefits from honest, ethical sales. With so many homes yet to install solar in the United States, there's enormous potential for all parties involved. We'll work together as industry professionals to chart a positive course, together.
The spirit of our compliance guidelines is simple, and summed up in 4 key points:
How We Approach Compliance
Our rules of engagement with partners follows a simple 1-2-3 sequence.
INTAKE: Intake the information or evidence of a compliance violation
INVESTIGATE: Request additional information or counter-evidence from the Certified Installer. Certified Installer has 48 hours to respond. Certified Installers are strongly encouraged to take additional precautions (details below) to ensure that strong counter-evidence is available in the event of extreme customer claims.
ACTION: Render a decision and take action.
Depending on the context of the situation, LightReach reserves the right to take any appropriate action, including but not limited to:
Clawback of funds
Termination of rep/state/org access
Org/Rep reported to Recheck
Standard Installer Verifications
Installers should take reasonable steps to protect their business against potential adverse customer claims. Rather than enforcing broad compliance requirements on all sales, we advise installers to take precautionary actions that work best for their business. We do however reserve the right to request specific items to verify proper sales steps were taken. Having concrete counterevidence can safeguard installers against adverse customer claims. Examples of common Standard Installer Actions are listed, but not limited to, the below.
Common Verification Methods
Written Recaps | Simple written recaps such as emails or text messages that recap key Energy Plan and general solar terms/information. Typically an easy way to ensure key information is put in writing. While homeowners do not necessarily have to reply, it is best practice to document an acknowledgement.
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Physical Documentation | Leave behinds, brochures, disclosures; many installers create their own disclosure documents for customer signoff; any & all forms of paper documentation recapping key terms/info.
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Installer Verification Call
| Installer verification/welcome calls, if offered, are often a helpful way to record key terms and details with the customer. While LightReach doesn't mandate a script, addressing key Energy Plan and solar terms, detailed further down in this article, is advised.
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Family Involvement | Ensuring any/all relevant family members or decision makers are involved with higher risk customer groups (particular elderly customers) and fully educated on the sale, and provided written recaps of key details.
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LightReach Right To Request
LightReach may require verification of precautionary steps from installers for accounts with higher-risk factors, at the discretion of our underwriters. Higher-risk factors include but are not limited to pricing, age, or market NPS scores. In such instances, installers are responsible for providing LightReach with a reasonable copy of the installer's verification step(s).
LightReach typically samples a percentage of accounts as standard practice, via Administrative Stipulations placed on the accounts. Partners receive standard stip notification emails in the event of this happening.
At the discretion of our underwriters, LightReach may elect to halt or cancel a deal in the event no standard installer actions or precautions were taken. In general, if LightReach selects an account for verification, we're looking for reasonable coverage of our above minimum criteria. However, in unique or extreme circumstances, LightReach may also review secondary criteria.
If in review, there are clearcut red flags, we will respectfully decline the deal.
Standard Installer Action: Criteria
Regardless of the exact verification method used, Installers should reasonably cover core basics of the solar deal and common friction areas. In the event of an account being stipulated to review installer verification, LightReach will review for coverage of (but not limited to):
Basic Info: Customer contact information, and the names & contact information of any family members included in the sale process (if applicable).
System Basics: Including size, production
Contract Basics: Including payment, escalator, term
Utility Bill Basics: Including that the customer will always have a utility bill, and that any electricity used beyond solar production will come from their utility.
No Incentives: That there were no incentives or material promises of any kind included in the contract.
Click to view additional tips & best practices
Click to view additional tips & best practices
Ask probing questions: Many partners wisely phrase certain questions on their verification steps to flush out any potential misunderstanding. This can also serve as a means to cover multiple topic areas with a single question. For example "Is there anything else you and your sales representative discussed what we did not cover here, or you would like to clarify more about?"-- This is a great example of a probing question which might help surface friction points such as incentives, notions of 'never having a bill', etc.
Know the common pain points: Customer escalations and poor NPS scores often focus around [1] A promise or misunderstanding of incentives and [2] Promises or misunderstanding around offset concepts (such as "I was told I would never have a utility bill"). Installers should consider these key areas when formulating a verification method.
Don't coach: We understand that a degree of guidance through verification may be necessary as part of a normal sale. But distinct signs of sales rep coaching (such as completing steps for, or otherwise directly answering for a customer, is grounds for the deal to be halted).
Avoid risks: Installers should take sensible steps to avoid high risk customers who may pose a threat to their business. Homeowners who appear or sound disoriented about their solar sale may require additional education to minimize risk of issues down the line. Homeowners who do not have an email cannot sign with LightReach, and while we do not expressly prohibit customers from creating emails for solar, they must belong solely to the customer and installers should document this in your verification. Ultimately, some homeowners simply may not be a good fit for our product, and installers are asked to use best judgement in proactively cancelling any customers who may not be a good fit for solar.
The More the Merrier: Installers are not limited to just one single verification step. Having multiple layers can go a long way to mitigating against adverse customer claims.
In general, if LightReach selects an account for verification, we're looking for reasonable coverage of our above criteria. However, in unique or extreme circumstances, LightReach may also review secondary criteria.
Click to view secondary criteria
Click to view secondary criteria
The verification was completed with the applicant themselves, and that the applicant is reasonably engaged.
There are no signs of sales rep coaching.
Key facts and details are articulated to the customer in a fully transparent manner, and the customer shows no signs of potential confusion.
Partner/Customer Transfer Policy
LightReach Policy
| LightReach takes the stance of an 'Open Market' Policy. |
LightReach Does Not... | Transfer customer agreements between partners. |
Action Required by Homeowners | Homeowners wishing to cancel With Certified Installer (A) and sign with a new Certified installer (B) must qualify and sign a new contract. This is in the interest of fairness to all of our Certified Installer partners. |
Subsidized Rate Plan Customer Policy
Some electric utilities offer specialized rate discounts to certain customer groups, such as low income or medical assistance/disability discounts. These programs can vary widely in scope and details. Common utility subsidized rate programs include:
California's CARE discount for those below 200% of the Federal Poverty Level (FPL).
Eversource Massachusetts' bill discount programs
Connecticut's bill discount programs
Eversource New Hampshire's FPL discount programs
Rhode Island's A-60 Rate program
Various low income bill credits / Percentage of Income Payment Plan (PIPP) programs in NJ, PA, CO, OH, NV, VA, IL, WI.
LightReach Policy
| LightReach does not expressly prohibit all subsidized rate plan customers. However, we do take reasonable precautions to ensure that applicable homeowners are aware of the potential impacts of solar on their rate plan.
In many cases, customers who pay the utility less will save less (or not at all) with solar, and may not be a good fit for our Energy Plan product. |
LightReach Does Not... | LightReach does not expressly prohibit all subsidized rate plan customers. |
Additional Precautions | All homeowners acknowledge our subsidized rate plan disclosure when they complete their standard Customer Agreement Confirmation (NTP requirement).
Homeowners may at their discretion contact LightReach to review their bill rate plan for potential solar impacts.
In such situations, LightReach will provide homeowners with transparent information about the impact of solar on their rate plan. It is therefore imperative for sales representatives to be cognizant of subsidized customers during the sales process, and avoid customers who may be negatively impacted by solar.
Generally, LightReach will provide information to customers and assess their rate plan based on the impact of going solar:
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