Although most of the provisions relate only to complaints, the proposed requirement for use of only "basic rate" numbers relates to all post-contract contact - mirroring the relevant provision of the Consumer Contract Regulations - albeit at least 12 month late.
Our major concern is that the revised rules have been drafted in apparent disregard of the forthcoming "Clear Call Rates for Everyone". Not only does this make them unnecessarily complex, it also serves to undermine the clarity which the new regime will introduce.
(We have written to Ofcom, copying the FCA, about the points made around consultation question 19. We have already published comment on this topic and more will follow shortly.)
Click on the image to view the text of our response.