In this case airline ticket was purchased from OTA, who charged my CC, so OTA is the merchant on my CC statement. OTA subsequently paid the airline (SQ) with a different CC which shows up on the ticket receipt. The ticket is issued on 618 SQ stock. The ticket was for flights on April 24 but all the segments were cancelled by the airline, who sent out cancellation emails.

I feel SQ should be required to comply with DOT rules and cannot avoid doing so simply because it sold its ticket through an OTA. I agree with the poster above that the OTA is merely acting as an agent of the airline. Apparently, SQ is being unresponsive to the OTA. I have followed through with the DOT. I am also talking to the CC issuer as the charge was made 10 months ago. We are talking several thousand dollars, and vouchers would be totally useless to us.