For RFS customers that pre-sign an agreement with a retailer for up to 24 months ahead of their service being delivered, do these customers fall under the OTS process?
For Business customers the proposal is to include customers with delivery lead times up to 6 months ahead of delivery. For consumer customers this is proposed to be 90 days. It would not be wise for a retailer to include customers with a RFS > 90 days as this could be used by their competitors to seek delivery ahead of the RFS. The retailer should also seek to confirm the legality of pre-ordering such a long time in advance and if their RFS customers could terminate such an agreement if they can get an alternative service prior to the 2-year date.
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