Telecom Commission Letter addressed to the Distribution List

Ottawa, 16 July 2019

BY E-MAIL 

File No. 1011-NOC2016-0293

To: Distribution List

RE: Wireless Code – 2019 Compliance Reports – device financing plan

Sir, Madam,

The Wireless Code (the Code) is a mandatory code of conduct for providers of retail mobile wireless voice and data services to individual and small business customers in Canada.

Commission staff is aware of a recent practice whereby some wireless service providers (WSPs) are now offering device financing plans to customers separate from the provision of wireless services. Commission staff is seeking information to better understand these device financing plans and how they are offered to customers.

The Appendix to this letter sets out questions that WSPs must answer by no later than 30 July 2019. WSPs must answer the questions on behalf of all their brands, including all primary and flanker brands. Footnote1

Should you have any questions concerning this request for information, please contact Guillaume Leclerc by e-mail at guillaume.leclerc@crtc.gc.ca.

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.

Yours sincerely,

Original signed by/

Scott Hutton
Chief, Consumer, Research and Communications

Distribution List
bell.regulatory@bell.ca;
geoff@brooketel.ca;
faye.hughes@brucetelecom.com;
regulatory@brucetelecom.com;
tom.sullivan@brucetelecom.com;
Regulatory.Matters@corp.eastlink.ca;
martha.facey@execulink.com;
Regulatory@sjrb.ca;
a.lawrence@hay.net;
grubb@hurontel.on.ca;
regulatory@icewireless.com;
lhallahan@mornington.ca;
knaylor@mornington.ca
reglementa@telebec.com;
amazza@suncor.com;
kyakimishyn@suncor.com;
regulatory@quadro.net;
rwi_gr@rci.rogers.com;
document.control@sasktel.com;
richard.biron@sogetel.com;
stephen.scofich@tbaytel.com;
david.wilkie@tbaytel.com;
regulatory.affairs@telus.com;
regulatory@tccmail.ca;
reglementa@telebec.com;
dennis.beland@quebecor.com;
Xplornet.Legal@corp.xplornet.com
kgugan@wightman.ca;
mlewis@lbhmedialaw.com;
harleen.sawhney@zoomermedia.ca;

Appendix - Questions

For the following questions, report separately for each brand.

Q1. Questions for all WSPs

  1. Confirm whether you are currently offering device financing plans (financing plans) to customers separate from the provision of wireless services.
  2. Confirm whether you are planning to, or are considering, offering customers financing plans.

Q2. Questions for WSPs that are offering or are planning to offer a financing plans

For WSPs that are planning to offer a financing plan, answer the questions below based on how you currently intend to implement such financing plans.

Financing plan

  1. What are the various terms offered to customers on the financing plans you offer?
  2. Can a customer change the terms of their financing plan? If so, explain the conditions under which a customer may do so.
  3. Can a customer make advance payments on their financing plan? If so, explain the effect that any advance payment can have on the customer’s financing plan, including the duration of the plan and monthly payments.
  4. Can a customer cancel their financing plan? If so, explain,
    1. the conditions under which a customer may cancel a financing plan,
    2. any consequences a customer may face when the financing plan is cancelled, and
    3. in particular, can a customer avail themselves to a competitive offer from a different WSP before their financing plan concludes? What consequences does that have on the financing plan?
  5. How are customers informed of the conditions and consequences related to the situations presented in a) through d).

Devices

  1. Which devices or types of devices are eligible for the financing plans you offer?
  2. Are there any limits to the number of devices or types of devices that can be acquired under a financing plan by a customer? For example, any limits on the number of devices imposed on a customer based on the number of subscribed lines.
  3. Can a customer upgrade or replace the device they have obtained under the financing plan? If so, explain the conditions under which a customer may do so, including how and when a customer may upgrade or replace the device.

Combination of a financing plan with a wireless service plan

  1. Can a customer obtain a financing plan without subscribing to a wireless service plan? If so, explain the conditions under which a customer may do so.
  2. Identify which wireless service plans can be combined with financing plans.
  3. Explain whether or not any of the financing plans you offer can be combined with any wireless service plan currently being offered.
  4. Can a customer still have a device subsidy when a financing plan is used in combination with a wireless service plan? If so, explain the impact of the financing plan on the device subsidy.
  5. What implications does the financing plan have on the early cancellation fees associated with the wireless service plan?

Upfront costs for customers

  1. Can a customer enter into a financing plan with a $0 down payment? If so, what are the conditions under which a customer may do so?
  2. List any upfront costs a customer may be charged in relation to the financing plans you offer.
  3. Explain the circumstances under which a customer may be charged any of the upfront costs listed above.
  4. Explain how and when these upfront costs are communicated to customers.

Sales channels and information provided to customers

  1. What are the sales channels, such as in store, online, door-to-door or over the phone, may a customer go through to obtain a financing plan?
  2. How are customers informed of the terms and conditions related to the financing plan across the different sales channels, including in store, online, door-to-door or over the phone?
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