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Ottawa, 22 May 2014

File number: 8665-C12-201212448

Mr. Jonathan E. Scott
Chief Financial Officer
Execulink Telecom Inc.
jonathan.scott@execulink.com

BY E-MAIL

Re: Wireless Code Implementation – Compliance Reports

Dear Mr. Scott:

In The Wireless Code Policy [1], the Canadian Radio-television and Telecommunications Commission (the Commission) established the Wireless Code, a new mandatory code of conduct for providers of retail mobile wireless voice and data services (wireless services). The Wireless Code applies to all wireless services provided to individual and small business consumers in all provinces and territories regardless of the status and business models of the Wireless Service Provider (WSP).

As required by paragraph 377 of the Wireless Code Policy, WSPs filed reports with the Commission in January 2014 detailing how they have implemented the Wireless Code [2]. CRTC staff reviewed these reports and considers that there are elements of WSPs' implementation that require further follow-up.

Therefore, you are asked to file answers to the attached questions on or before 29 May 2014.

This letter and all subsequent correspondence form part of a public record. As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, WSPs may designate certain information as confidential. WSPs must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.[3]

Yours sincerely,

ORIGINAL SIGNED BY /

Nanao Kachi
Director, Social and Consumer Policy, CRTC

[1]Telecom Regulatory Policy CRTC 2013-271, 3 June 2013, CRTC
     File number 8665-C12-201212448

[2] https://applications.crtc.gc.ca/DocWebBroker/OpenDocument.aspx?Key=62279&Type=Notice

[3] http://laws-lois.justice.gc.ca/eng/regulations/SOR-2010-277/index.html

Enclosure
Questions

  1. Staff notes that Execulink has submitted its entire sample contract and critical information summary in confidence and has not provided an abridged version for the public record. All other WSPs filed their sample contracts and critical information summaries on the public record.

    2. Please review the designation of these documents and, where Execulink wishes to designate individual pieces of information in these documents as confidential, provide detailed rationale to justify why disclosure of this information is competitively sensitive for Execulink when this is not the case for any other WSP. Where individual pieces of information are not competitively sensitive, provide a copy of these documents for the public record (either in whole or as an abridged version).

  2. As set out in paragraph 253 of the Policy, "WSPs must provide a 15-calendar-day (minimum) trial period for contracts where the consumer is subject to an early cancellation fee. During the trial period, customers can cancel their contract without penalty if they have (i) used less than the prescribed usage; and (ii) returned any mobile device provided by the WSP in near-new condition, including original packaging."

    3. As outlined in the contract sample you provided, customers have a trial period of 14 days. Explain how your contract respects the policy outlined above.

  3. Paragraph 253 of the Policy (above) outlines the mandatory trial period.

    Explain how a customer can form a complete opinion as to the quality of the received service for their needs with a trial period that includes a maximum of 30 minutes of airtime and 50 MB of data usage.

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