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Procedural letter

Our reference: 8656-G44-201207580

Ottawa, 13 August 2012

By e-mail:

Re: Application for ownership review of TELUS Corporation and TELUS Communications Inc.

Mr. Woodhead,

This is in reference to an application filed on 20 July 2012, by Globalive Wireless Management Corp., doing business as WIND Mobile (WIND), and naming TELUS Corporation (TELUS) and TELUS Communications Inc. as respondents.

Section 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information, particulars or documents where needed.

Comprehensive answers to the following questions, including rationale and supporting information, are to be provided by 24 August 2012.

  1. TELUS Communications Company’s 23 July answer (Answer), states that 32.59% of TELUS’ voting shares are held by non-Canadians.
    1. Explain, in detail, how this figure was determined, including a breakdown of the ownership of shares in each CUSIP by Canadians and non-Canadians.
    2. Provide a description of the role and actions taken by all parties involved, including CDS Clearing and Depository Services Inc. (CDS) and Computershare Trust Company of Canada (Computershare), in determining this figure.
    3. In arriving at this figure (32.59%), please clarify what was required or requested of the beneficial owners of TELUS shares, in order to determine their residency and citizenship or permanent residency status.
  2. With reference to paragraph 11 of TCC’s Answer:
    1. Describe the “appropriate information” that is gathered by CDS from the “Participants” (as that term is defined in paragraph 9 of the Answer), and
    2. Detail the supporting actions or evidence that CDS requires from its Participants to support their declaration that they are “not aware of any violation or breach”.
  3. With respect to the TELUS-CDS agreement referenced in TCC’s Answer:
    1. Explain in detail the CDS procedure for confirming residency and citizenship or permanent residency status of TELUS’ beneficial shareholders.
    2. Explain what actions are taken by CDS and/or Computershare to “cause each one of its ‘Participants’... to comply with TELUS’ foreign ownership” procedures.
  4. With reference to WIND’s 4 July 2012 submission, provide a detailed response to the following:
    1. Were all TELUS shareholders required to declare their residency, citizenship or permanent residency status, and/or whether they meet the definition of “Canadian” set out in the Canadian Telecommunications Common Carrier Ownership and Control Regulations? If so, please provide a summary of the shareholder declarations and explain, if applicable, why the percentage of Canadians differs from the percentage reflected in TCC’s Answer.
  5. WIND contends that brokers, investors and other financial intermediaries are not aware of TELUS’ procedures regarding Canadian ownership.
    1. Clarify how TELUS and its representatives inform financial participants of the procedures used to manage non-Canadian ownership of voting shares, citing recent examples of such communication.

A copy of this letter will be added to the public record of the proceeding.

Yours sincerely,

Paul Godin
Director General
Industry & Market Analysis

c.c: WIND mobile

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