Telecom Commission Letter adressed to the Distribution List

Ottawa, 30 August 2019

BY E-MAIL 

Our reference: 1011-NOC2019-309

To: Distribution List

RE: Wireless Code – Device financing plans – Request for information

Sir, Madam,

The Commission initiated a proceeding, Telecom Notice of Consultation CRTC 2019-309 (the Notice),Footnote1 to consider whether device financing plans, including those with terms greater than 24 months, are compliant with the Wireless Code. Further, it appears to the Commission that, as of the date of the Notice, Bell Canada, Iristel Inc. (Iristel), Rogers Communications Canada Inc. (RCCI) and TELUS Communications Inc. (TCI) have offered the device financing plans in question. The Commission, therefore, initiated a proceeding asking these wireless service providers (WSPs) to show cause why they have not committed a violation by offering device financing plans that may be contravention of the Wireless Code.

As indicated in the Notice, WSPs who have confirmed through their responses to the 16 July 2019 request for informationFootnote2 that they are offering device financing plans, i.e, Bell Canada, Iristel Inc., Rogers Communications Canada Inc., SaskTel, and TELUS Communications Inc., are to respond to the request for information contained in the appendix to this letter by no later than 16 September 2019. WSPs must answer the questions on behalf of all their brands, including all primary and flanker brands.Footnote3

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.

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

Yours sincerely,

Originally signed by Antica Corner on behalf of

Nanao Kachi
Director
Social and Consumer Policy

Distribution List

bell.regulatory@bell.ca
regulatory@icewireless.com
rwi_gr@rci.rogers.com
document.control@sasktel.com
regulatory.affairs@telus.com


Appendix - Questions

For the following questions, report separately for each brand.

Questions for all WSPs

Q1. Market adoption of device financing plans

  1. What date did you first start offering device financing plans?
  2. How many customers entered into a device financing plan from the date you started offering these plans up until  2 August 2019?
  Mobile wireless devices Tablets Smartwatches or other devices Total
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
Total        
  1. For the period from when you started offering device financing plans up until 2 August 2019, how many customers entered into new wireless service plans?
  2. For the customers who entered into a device financing plan prior to 2 August 2019 as identified in Q1.b) above, how many combined their device financing plan with a device subsidy?
  Mobile wireless devices Tablets Smartwatches or other devices Total
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
Total        
  1. For the customers who entered into a device financing plan prior to 2 August 2019 as identified Q1.b) above, what is the average minimum monthly bill of their associated wireless service plan?
  Mobile wireless devices Tablets Smartwatches or other devices Overall
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
  1. How many customers entered into a device financing plan on or after 2 August 2019?
  Mobile wireless devices Tablets Smartwatches or other devices Total
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Total        
  1. How many customers entered into a new wireless service agreement on or after 2 August 2019?
  2. For the customers who entered into a device financing plan on or after 2 August 2019 as identified in Q1.g) above, how many combined a device financing plan with a device subsidy?
  Mobile wireless devices Tablets Smartwatches or other devices Total
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
Total        
  1. For the customers who entered into a device financing plan on or after 2 August 2019 as identified in Q1.f) above, what is the average minimum monthly bill of their associated wireless service plan?
  Mobile wireless devices Tablets Smartwatches or other devices Overall
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        

Q2. Nature of the device financing plan

  1. For the customers that entered into a device financing plan, as identified in Q1.b) or f) above, what is the average initial balance of that device financing plan, i.e. what is the average cost of the associated device that is being financed?
  Mobile wireless devices Tablets Smartwatches or other devices Overall
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
  1. For customers that entered into a device financing plan, as identified in Q1.d) and Q1.h) above, what is the average device subsidy that was offered, if any, in addition to the device financing plan?
  Mobile wireless devices Tablets Smartwatches or other devices Overall
With a 24 month term        
With a 36 month term        
With any other term, indicating the term length        
Overall        
  1. At what point in a wireless service plan can a customer obtain a device financing plan, with or without a device subsidy? In other words, can a customer obtain a device financing plan at any time during the duration of their wireless service plan, or is it limited to the time at which the wireless service plan is entered into?

Q3. Documentation provided to customers

Provide a copy of the documents provided to customers entering into a new device financing plan.

This should include the following:

Questions to Saskatchewan Telecom

Q3. “Plus Pricing” plans

In your response to the request for information issued 16 July 2019, you noted that “SaskTel does not offer a unique suite of financing plans similar to the recent action of other Canadian carriers” , but that “SaskTel does offer customers the ability to finance the subsidized price of a device, which is termed in the market as 'Plus Pricing'.”

Answer the following questions regarding your “Plus Pricing” plans.

  1. Explain how “Plus Pricing” differs from device financing plans offered by other WSPs, in particular:
    1. Can a customer avail themselves of a competitive offer from a different WSP before their “Plus Pricing” plan concludes?
    2. What are the consequences of cancelling the associated wireless service plan prior to the conclusion of the ‘’Plus Pricing” plan?
    3. Can a customer have a device subsidy with a “Plus Pricing” plan that is used in combination with a wireless service plan? If so, explain the impact of the “Plus Pricing” plan on the device subsidy.
    4. What implications does the “Plus Pricing” plan have on the early cancellation fees associated with the wireless service plan?
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