We further recommend that the Commission promptly issue a Notice of Proposed Rulemaking (“NPRM”) regarding consumer and competitive benefits of customer retention marketing practices. Given the prevalence of intermodal and bundled service competition, we recommend that such an NPRM conclude that customer retention marketing practices be made consistent across all platforms.

32. The Bureau therefore recommends that the Commission adopt a Notice of Proposed
Rulemaking to seek comment on whether the Commission should adopt specific rules addressing certain
practices, and, if so, what form those rules should take. Whatever form they take, the Bureau
recommends that they be consistent across various service platforms. The Commission has acted in
several areas to create parity across different platforms,74 and the Bureau suggests that the current market
for bundled, facilities-based service requires consistency.