I'd take there "pooling" system with a large grain of salt.

We ran the numbers across our userbase and we'd be out of business within a month if we tried that. Isn't it odd that only TI can offer this special pooling business. I can't possibly believe its average customer usage profile is so completely different to all the other ISPs out there that it makes it possible for them.
Also I doubt any money changes hands or they pay VAT etc. How does a company invoice itself?
Regarding ISPA, we have a discussion going and legal counsel looking into it and will advise when we have clarity.
Cheers