The Federal Communications Commission wants to know if consumers are getting the advertising and billing information they need to make good choices about their broadband and/or mobile phone plans, and the answers are coming in from trade and reform groups. Not surprisingly, they read like alternate reality documents. To peruse CTIA - The Wireless Association's 157-page response to the FCC, you might come away with the impression that mobile owners swoon with joy upon the arrival of their monthly statement. Meanwhile the comments of the Consumer Federation of America and five similar groups portray a dark, foggy ad landscape where Jane Q. Broadband-user stumbles about, at best only vaguely aware of how many ways her pocket is about to be picked.

But buried within the mountain of PDF feedback the FCC is getting is a somewhat intriguing idea. Why not simplify the whole disclosure process, the agency's inquiry asked, by borrowing something from the regulated credit card industry: a "Schumer Box," as it is called.

CFA and the gang think it's a grand plan, calling the box "a consumer-friendly format to provide specific and easily comprehensible information, standardized across service providers to enable easy comparison." Needless to say, CTIA is far less enthusiastic about the proposal, warning that imposing it on wireless could result in a reduction of services.

So what is this box, anyway?

Assertive presentations

The Schumer Box, you will not be surprised to learn, is named after United States Senator Charles Schumer (D-NY), who championed the Truth-in-Lending legislation that requires credit card companies to carefully format their services to consumers as so: long term interest rates in at least 18 point type, and other important stuff in 12 point type.

Inside the box, the company must disclose seven categories of information: any annual fee, the annual percentage rate for purchases, rates for cash advances and other services, grace periods, the card's system of calculating interest, and whatever the card dings for late payments or for going over your credit limit, among other monetary head noogies.

The box requirement went into effect in 2000. The United Kingdom implemented its own version in 2004 (they don't call it a Schumer box there, of course).

New America Foundation's prototype Schumer Box for broadband customers

Most consumer groups are big boosters of Schumerizing the broadband/wireless industry. The New America Foundation has gone so far as to offer the FCC its own prototype of a Schumer Box, applied to broadband. The ExampleCom "Ultra 15 Mbps" broadband service's boxed bill starts by disclosing the "advertised speed:" 15 Mbps downstream/2 Mbps upstream. Then comes the "Minimum Speed at Border Router:" 8Mbps downstream / 384Kbps upstream, followed by the "Minimum Reliability/Uptime:" 96 percent.

The rest of the disclosure document outlines ExampleCom's service guarantee terms, its monthly service price and duration of that price if it's a long term plan, service limits ("Exceeding 100GB calendar week considered excessive use" in this case), extra costs like installation fees, the technology being used to provide service, and ExampleCom's privacy policies.

"This Broadband Truth-in-Labeling disclosure must be shown to the consumer as part of the sign-up process," New America urges, "and must be assertively presented again any time the ISP decide to alter the terms in such a way that alters the facts on the original Broadband Truth-in-Labeling disclosure."

No more fine print

Consumer groups say something like this is necessary because wireless/broadband buyers are "bombarded" with confusing, often contradictory data about the services companies offer. "When trying to find clear information from providers about actual rather than advertised speeds;" they write, or about other costs, barriers, and fees, "most consumers can’t get a clear signal through all the advertising noise."

CFA et al cite a Verizon mailer advertisement as an example (it's included at the bottom of their filing in Appendix B). The ad offers $19.99 a month for DSL, but only in fine print does the reader learn that a one-year agreement is required and the price goes up after six months. "Fine print is also used to disclose while effectively hiding a one time charge of 'up to $55,' and mandatory subscription to Verizon telephone service, in order to receive the service at the advertised base price," the commentary notes.

Highly unreliable

CTIA takes issue with assertions that advertising for wireless services is deceptive. But the trade group also raises concerns about various aspects of the Schumer Box idea. First, CTIA notes that wired and wireless broadband services are fundamentally different in some key ways. It's much harder to predict actual wireless speeds, as opposed to broadband speeds, the group contends—citing the challenge of assessing how many consumers are sharing a wireless area, as opposed to, say, a broadband cable node. So forcing wireless companies to come up with a guestimate "would be a highly unreliable way of providing consumers information about the service."

"The likely result of the imposition of a 'Schumer Box' would be a reduction in innovative service offerings and bundles," CTIA warns. Still, it's probable that Schumer Box fans will respond that wireline and wireless differences can be taken into account when designing a Schumer format for these services. Our guess is that there will be more thinking inside the box about this proposal.