Mark Pestronk
Q: I would like to train my travel agent employees about how to comply with the DOT's full-price and codeshare rules during their phone and in-person conversations with clients. I know that my agents don't always follow those rules, and the DOT has been fining travel agencies for noncompliance. Can you succinctly state the rules that apply to oral statements such as airfare quotes and flight availability so that I can tear out your column and distribute it to all of my staff? Can you give examples of what to say and not to say?
A: When it comes to phone and in-person conversations, as opposed to emails and advertisements, there are just two DOT rules to remember: the full-price quote rule and the codeshare rule.
The rules apply to your travel agents who quote airfares, regardless of whether your agency or a third party such as a host agency issues tickets.
• Full-price rule: You must always quote air travel prices by stating the full price, including all taxes and fees, even including your agency's transaction or service fee per ticket.
After you quote the full price including all fees, you are allowed to break down the total into the airfare and your fee, but you don't have to do so. Although you could theoretically reverse the order and start with the breakdown, I don't recommend it, as you may forget to state the total price after the breakdown.
The full-price rule also applies to the total price of any package that includes air as part of the price, such as a cruise line's air-sea package or a tour operator's inclusive tour. So if a cruise line advertises an air-sea package as "$1,000 plus $100 taxes and fees," you can't quote it that way. You must quote it at the price that includes all the taxes and fees, which is $1,100, although you can then break it down like the cruise line does.
On the other hand, if a wholesaler's vacation package consists of a resort component and an air component, each of which may be purchased separately, you are free to quote the resort stay alone as "$999 plus local taxes."
• The codeshare rule: When you first offer a codeshare flight, or when you first respond to an inquiry about a codeshare flight, you must always say three things: the name of the airline with the flight designator, the corporate name of the transporting carrier and any other name under which service is held out to the public.
A "codeshare" is a commuter flight with a major carrier designator or a major carrier flight with an alliance partner's designator.
So for the commuter flight, you must say, "Delta 9876 is operated by Endeavor Air operating as (or doing business as) Delta Connection."
For the alliance codeshare, you must say, "Delta 5432 is operated by Air France." For trips with multiple codeshare legs, you have to make these statements for each codeshare leg, even for legs entirely outside the U.S.
You must make these disclosures upfront; you cannot wait until the reservation is about to be finalized or until the confirmation is issued.