Telecom Commission Letter Addressed to David Watt (Rogers Communications Inc.)

Ottawa, 24 July 2018

Our reference: 8620-P8-201800756


David Watt
Senior Vice President, Regulatory
Rogers Communications Inc.
350 Bloor Street East, 6th Floor
Toronto, Ontario M4W 0A1

Subject: Application on 5 February 2018 by Public Interest Advocacy Centre (“PIAC”) and National Pensioners Federation (“NPF”) regarding Rogers’ prepaid services

Dear Mr. Watt:

On 5 February 2018, Public Interest Advocacy Centre and the National Pensioners Federation (together, PIAC-NPF) submitted a Part 1 application regarding Rogers Communications Inc. (Rogers’) new policy on prepaid wireless service account balances.

In order for the Commission to properly dispose of PIAC-NPF’s application, further information is required from Rogers.

Accordingly, Commission staff requests that Rogers respond to the attached request for information no later than 3 August 2018, serving a copy to all other parties to the proceeding. Please respond to all questions in one document.

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

Parties will be able to submit comments in reply to Rogers’ responses no later than 8 August 2018.

Procedures for filing

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. Parties 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.


[Original signed]

Nanao Kachi
Director, Social & Consumer Policy
Consumer Affairs and Strategic Policy

c.c.: Distribution List

Paula Bath, CRTC / Le CRTC:
Rogers Communications Inc.:
Telus Communications Inc.:
Bell Canada:
Union des consommateurs:
Mr. P. Delannoy:

Attachment 1 – Request for Information

  1. Affected customers

    How many customers does Rogers estimate may be affected by its proposed change to its large prepaid balance policy?

    • Provide a breakdown of how many Rogers’ customers have prepaid balances, and what amount and percentage of these have balances in excess of $150 at this time.
  2. Impact on customers

    In its intervention, dated 12 March 2018, Rogers’ stated that should any new or existing prepaid customers exceed the $150 proposed cap prior to the effective date of the change, Rogers will contact them to present options for using their balance in a way that is right for themFootnote1 .  Rogers further stated that “Our customer service agents have subsequently been reviewing options with customers to find solutions on how to best use these dormant amounts.”

    1. Explain, in detail, all the methods Rogers is using to inform both new and existing prepaid customers about the policy change prior to 31 December 2018.
    2. List and describe in detail the various solutions Rogers is offering to customers to use these amounts. Provide concrete examples.
    3. If, as of the date that the new large prepaid balance comes into effect, certain customers continue to have balances in excess of $150, will Rogers reduce that customer’s balance to $150 or does Rogers have a solution in place to otherwise address this situation? 
    4. Provide an overview of the number of complaints, if any,that you have received about this policy change excluding inquiries.
  3. Update to terms of service and contracts

    Rogers stated by the time the new policy is introduced at the end of 2018, Rogers will have updated its service contracts, websites and terms of service with relevant details about the changeFootnote2 .

    1. When will the new service contracts, websites and terms of service be updated and in effect?
    2. Submit a copy of the planned amended terms and conditions that reflect the new prepaid balance policy, and identify the relevant provisions.
  4. Comparison to Telus’ Large Prepaid Balance Policy

    In Telecom Decision CRTC 2015-211Footnote3 , at paragraph 17, the Commission summarized the options for solutions provided by Telus to customers affected by its proposed policy regarding prepaid account balances. How are the options for solutions Rogers is offering to its customers similar to or different from the options referenced in Telecom Decision 2015-211?

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