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Compliance and Enforcement and Telecom Decision CRTC 2020-185

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Ottawa, 9 June 2020

Public record: 8638-B2-201905879

Bell Canada – Application to allow Bell Canada and its affiliates to block certain fraudulent and scam voice calls on a trial basis

The Commission approves Bell Canada’s application to allow Bell Canada and its affiliates to block certain fraudulent and scam voice calls on a 90-day trial basis. The Commission’s determinations in this decision will help ensure that the potential benefits of the trial are extended to the largest number of Canadians possible, while mitigating any negative impact on legitimate telecommunications.

Application

  1. The Commission received an application from Bell Canada, on its own behalf and on behalf of its affiliates (collectively, Bell Canada et al.), dated 24 July 2019 and revised on 27 August 2019, in which they requested the Commission’s approval to conduct a 90-day trial to block certain known and verified fraudulent and scam voice telephony calls received or transmitted from, to, or over their networks.
  2. Bell Canada et al. indicated that, in accordance with the Commission’s determinations in Compliance and Enforcement and Telecom Regulatory Policy 2018-484, they were finalizing the implementation of Commission-mandated network-level universal call blocking (hereafter, UCB). In anticipation of the UCB requirement, Bell Canada et al. submitted that they had reconfigured their Signaling System 7 (SS7) networks and deployed call-blocking tools at their consolidated SS7 gateways and international gateways. Bell Canada et al. added that they can build upon the call-blocking tools and combine them with artificial intelligence (AI) and machine learning to potentially block additional types of fraudulent and scam calls.
  3. Bell Canada et al. proposed to leverage AI to analyze telecommunications traffic in order to flag anomalies that suggest possible fraudulent and scam activity. These anomalies would then be subject to review and, if fraudulent or scam activity is verified, Bell Canada et al. would block subsequent related calls associated with the anomalous activity at the network level.
  4. Given that the call-blocking system would be implemented at a network-wide level, every call originating on, terminating on, or merely transiting through Bell Canada et al.’s networks would be subject to analysis and potential blocking. Additionally, due to the network layer at which the blocking occurs, there is no notification given to either the originator or the intended recipient that a call has been blocked. Only voice calls would be subject to this system; text messages and other telecommunications would not be affected.
  5. Bell Canada et al. designated significant portions of their application as confidential under section 39 of the Telecommunications Act (the Act). They stated that the disclosure of certain details, particularly the methodology used in assessing calls, could be reasonably expected to result in material gain for bad actors, compromise the efficacy of Bell Canada et al.’s proposed call-blocking system, and perpetuate significant financial harm to Canadians targeted by fraudulent and scam phone calls.
  6. The Commission issued its determinations regarding Bell Canada et al.’s claims for confidentiality and interveners’ requests for disclosure in Compliance and Enforcement and Telecom Decision 2020-7. The Commission acknowledged Bell Canada et al.’s concern that providing certain details of their call-blocking methodology on the public record may provide a material advantage to those seeking to evade the companies’ system for the purpose of victimizing Canadians. The Commission also acknowledged the concerns of interveners who argued that the lack of available information impeded their ability to provide meaningful comments on Bell Canada et al.’s application.
  7. As a result, the Commission directed Bell Canada et al. to disclose certain information on the public record, and to disclose other confidential information to interveners who signed a non-disclosure agreement (NDA) proposed by Bell Canada et al.
  8. The Commission received interventions regarding Bell Canada et al.’s application from Dr. Fenwick McKelvey and Dr. Reza Rajabiun; Mr. Marc Nanni; Mr. Mark Phillips; Allstream Business Inc. (Allstream); the Canadian Network Operators Consortium Inc. (CNOC); the Internet Society Canada Chapter (ISCC); Iristel Inc., on its own behalf and on behalf of Ice Wireless Inc. (Iristel); Quebecor Media Inc., on behalf of Videotron Ltd. (Videotron); Rogers Communications Inc. (RCCI); and TELUS Communications Inc. (TCI).

Background

  1. Given the essential role that telecommunications play in the lives of Canadians, the Commission considers that protecting Canadians when accessing the telecommunications system is of fundamental importance. The Commission has recognized that a layered approach is required to achieve this objective and, to that end, has conducted a number of proceedings to consider various measures to protect Canadians against unwanted unsolicited and illegitimate calls. For example, in Compliance and Enforcement and Telecom Regulatory Policy 2018-484, the Commission required Canadian carriers and other telecommunications service providers (TSPs) that provide voice telecommunications services to implement UCB to the extent set out in that decision,Footnote 1 unless they offered call filtering solutions within the time frame prescribed for the implementation of UCB. The Commission has also mandated the implementation of other measures to empower Canadians to protect themselves from nuisance calls that will allow for the authentication of caller identification (ID) information and for call tracing.Footnote 2
  2. The Commission recognizes that fraudulent and scam calls pose a significant threat to Canadians and the Canadian telecommunications infrastructure; nevertheless,    any system that involves call blocking at the network level calls for scrutiny to ensure that it is carefully designed to operate in the public interest.

Should the Commission approve Bell Canada et al.’s application pursuant to section 36 of the Act?

  1. Pursuant to section 36 of the Act, a Canadian carrier cannot “control the content or influence the meaning or purpose of telecommunications carried by it for the public” except where the Commission approves otherwise. The Commission has previously expressed the view that the requirement to obtain approval pursuant to that section arises when a carrier seeks to block calls.Footnote 3 The Act does not set out parameters to guide the Commission’s exercise of this discretionary power, aside from the generally applicable requirements that it exercise its authority (i) with a view to implementing the telecommunications policy objectives set out in section 7 of the Act, and (ii) in compliance with the 2006 Policy DirectionFootnote 4 and the 2019 Policy Direction.Footnote 5
  2. The majority of interveners opposed Bell Canada et al.’s application. Some of those interveners argued that Bell Canada et al.’s proposal would undermine existing Commission-imposed measures, and other parties addressed the appropriate definition for fraudulent and scam calls. The principal concerns raised by the opposing interveners generally related to (i) the fact that the methodology for determining which calls to block would apply not only to calls to and from Bell Canada et al.’s customers, but also to traffic only transiting their networks; (ii) the potential for false positives;Footnote 6 and (iii) the extent and scope of information that Bell Canada et al. would be reviewing to determine whether to block calls.   
  3. The Commission accepts that successfully blocking verified fraudulent and scam calls would benefit Canadians and telecommunications networks, and would therefore be in the public interest. In deliberating on whether to authorize Bell Canada et al. to implement its call-blocking proposal, the Commission assessed the concerns raised by interveners and considered whether they outweigh the benefits of the proposal. In so doing, the Commission has also evaluated Bell Canada et al.’s proposal to determine whether it has been, or could be, sufficiently tailored to minimize any such valid concerns.   
  4. In light of the above, the Commission has considered the following issues in determining whether to approve Bell Canada et al.’s application pursuant to section 36 of the Act:
    • Would Bell Canada et al.’s call-blocking system have a negative impact on current regulatory measures designed to mitigate nuisance and fraudulent telecommunications?
    • Should the Commission accept Bell Canada et al.’s definition of fraudulent and scam calls for the purposes of their proposed trial?
    • Should Bell Canada et al. be allowed to block calls merely transiting their networks?
    • Are there risks of false positives and, if so, do any such risks outweigh the benefits of the proposed trial?
    • How is the data used or generated by Bell Canada et al. during the proposed trial to be handled?

Would Bell Canada et al.’s call blocking system have a negative impact on current regulatory measures designed to mitigate nuisance and fraudulent telecommunications?

Positions of parties

  1. Videotron submitted that the companies’ proposal would cause consumer confusion between the measures that are specifically mandated by the Commission for all TSPs and those undertaken by Bell Canada et al. Mr. Nanni submitted that Bell Canada et al.’s system would eliminate consumers’ choice of call-blocking measures.
  2. Bell Canada et al. submitted that their proposed system is intended to complement measures already mandated by the Commission, namely UCB and STIR/SHAKEN.Footnote 7 They indicated that the system is another effort to combat fraudulent and scam calling schemes by capturing calls that might evade existing systems.

Commission’s analysis and determinations

  1. The Commission finds that there is no specific overlap between the mechanisms proposed by Bell Canada et al. in their application and those required pursuant to Compliance and Enforcement and Telecom Decision 2018-484.Footnote 8Calls that fall under the criteria of UCB will continue to be blocked at a network level independently of any additional measures taken by Bell Canada et al.
  2. In the case of calls blocked by Bell Canada et al.’s system that were ultimately destined to TSPs that elected to offer an opt-in call filter in place of UCB, possible negative impacts would be limited to instances of false positives whereby a consumer has opted to allow calls from a specific caller, but the call is blocked regardless. The issues associated with false positives are discussed below.
  3. Accordingly, the Commission considers that Bell Canada et al.’s proposed trial would not have a negative impact on existing regulatory measures; rather, it would complement these measures by blocking verified fraudulent and scam calls that would otherwise reach consumers.

Should the Commission accept Bell Canada et al.’s definition of fraudulent and scam calls for the purposes of their proposed trial?

Positions of parties

  1. Allstream and CNOC submitted that Bell Canada et al., in their application, did not provide a clear definition of what they consider to be fraudulent and/or scam calls.
  2. In response, Bell Canada et al. proposed the following definition:

    A fraudulent and/or scam call means a voice telecommunications call that attempts, by deceit, falsehood, or other fraudulent means, to defraud a person, organization, or the public of any property, money, valuable security, or any service.

  3. They further submitted that only voice telecommunications will be included in the trial, and that for the purposes of the trial, certain calls at a higher risk of being falsely flagged are excluded from the above definition. Bell Canada et al. provided a description of this class of calls to the Commission in confidence.

Commission’s analysis and determinations

  1. The Commission considers Bell Canada et al.’s parameters and definition of fraudulent and/or scam calls to be clear and specific enough to be reasonably understood by all interested parties and stakeholders.
  2. Accordingly, the Commission accepts Bell Canada et al.’s definition of fraudulent and/or scam calls for the purposes of its call-blocking proposal.

Should Bell Canada et al. be allowed to block calls merely transiting their networks?

Positions of parties

  1. Allstream, CNOC, Iristel, the ISCC, Videotron, Dr. McKelvey and Dr. Rajabiun, and Mr. Nanni all objected to Bell Canada et al.’s proposal to subject third-party traffic to potential blocking. Under this system, even telecommunications traffic merely transiting Bell Canada et al.’s networks would be subject to analysis and potential blocking. The above-noted parties generally argued that if Bell Canada et al.’s application were to be approved, it should only be in relation to the traffic originating from or directed to Bell Canada et al.’s own customers.
  2. The ISCC further argued that the system should operate on an opt-in basis.
  3. Allstream submitted that the proposed trial, if approved, should be subject to Commission and industry oversight to ensure that it is implemented in a competitively neutral way. It also submitted that Bell Canada et al. should be obliged to submit reports to the Commission and to other TSPs outlining the number of blocked calls originating from and destined to those providers’ networks.
  4. Iristel and Dr. McKelvey and Dr. Rajabiun drew parallels between Bell Canada et al.’s proposal and spam email filters, stating that such systems take a great deal of time and resources to develop effectively. Dr. McKelvey and Dr. Rajabiun submitted that flagging calls for consumers rather than blocking them would be a more effective solution to the issue of fraudulent calls.
  5. Allstream, CNOC, the ISCC, and Videotron argued that blocking transiting traffic may cause issues for customers of third-party TSPs, and that those TSPs would be unable to effectively address the issues, in particular because their customers may not be aware as to why or by whom their calls are being blocked.
  6. Allstream, CNOC, and Mr. Nanni also drew attention to Bell Canada et al.’s position in the telecommunications industry, which would mean that a significant portion of all telecommunications traffic may transit the companies’ networks at some point, thus exposing such traffic to possible blocking.
  7. RCCI submitted that Bell Canada et al.’s proposed system and trial, if approved, should be applied uniformly across all of their trunks, thereby subjecting all traffic to equal treatment. TCI submitted that approval of Bell Canada et al.’s application would lead to useful information being generated regarding the criteria for approving similar network-level call-blocking systems on a permanent basis.
  8. Bell Canada et al. submitted that it is not technologically possible to limit the proposed trial and associated call-blocking system to terminating calls or to implement an opt-in procedure, as some interveners have suggested, and that with the exception of traffic terminating on their own networks, they are unable to determine which TSP would be the terminating carrier of a given call. Bell Canada et al. further submitted that it is not possible for their technology to effectively target any given originating TSPFootnote 9 because it operates on a different level from, and thus does not retrieve, the necessary information required to engage in such a practice.
  9. Thus, within Bell Canada et al.’s system, transiting and terminating traffic receive consistent treatment, and no undue preference or discrimination can be shown to any particular TSP. They pointed to RCCI’s submission as support for their approach.
  10. Bell Canada et al. disagreed with Allstream’s submission that industry oversight of their proposed trial should be required. Bell Canada et al. argued that such oversight would have no legal or regulatory basis, and that the Commission has the jurisdiction, authority, and expertise to establish and oversee all necessary safeguards in respect of the trial. To that end, Bell Canada et al. further detailed their willingness to provide to the Commission, on a confidential basis, any information that it might request, such as the number of blocked calls, the number of individually blocked originating line identifications, types of fraudulent and scam calls blocked, and the numbers of any false positives.

Commission’s analysis and determinations

  1. The Commission accepts Bell Canada et al.’s submission that it is not technologically possible for them to limit the proposed trial and associated call-blocking system to terminating calls or to implement an opt-in procedure, and that with the exception of traffic terminating on their own networks, they are unable to determine which TSP would be the terminating carrier of a given call. The Commission also accepts Bell Canada et al.’s submission that they would not be retrieving the information that would be required to effectively target any given originating TSP, in part because the system does not retrieve information from the Local Number Portability database.
  2. The Commission considers that the potential advantage of a network-level call-blocking system that would encompass transiting traffic is that it would extend to all consumers making use of telecommunications networks (not just customers of Bell Canada et al.) the benefit of blocking of fraudulent calls, as well as the additional benefit of reducing congestion on all telecommunications networks. The Commission also notes that by operating the call-blocking system at the network level, Bell Canada et al. would be able to review and provide to the Commission details relating to the efficacy of call-blocking systems in mitigating the impact of fraudulent and scam calls on consumers on a large scale.
  3. Based on the above, the Commission considers that the benefits of having the call-blocking trial apply to transit traffic outweigh the risks, if any. Further, to the extent that there are any risks, they can be addressed as discussed below.  
  4. As noted above, Bell Canada et al.’s network-level implementation would mitigate their ability to target traffic of any particular TSP. Nevertheless, any inappropriate negative impacts on TSPs could be addressed under subsection 27(2) of the Act. Pursuant to that provision, Bell Canada et al. are prohibited from engaging in unjust discrimination against another TSP and its telecommunications traffic or conferring an undue preference in favour of themselves. 
  5. The Commission acknowledges that TSPs may be unable to resolve customer complaints about calls not terminating. The Commission considers that concerns about the impact on TSPs, and their customers, could be addressed by imposing various requirements on Bell Canada et al. to deal with any such complaints in an expedient and complete manner.
  6. Finally, the Commission considers that it could monitor the effect of the proposed trial on TSPs by requiring Bell Canada et al. to submit reports regarding the trial’s progress. Implementing robust reporting measures would help the Commission ensure that Bell Canada et al.’s system operates in a manner that respects the companies’ existing obligations.
  7. In light of the above, the Commission rejects the objections to Bell Canada et al.’s proposed trial on the basis that it applies to transit traffic.

Are there risks of false positives and, if so, do any such risks outweigh the benefits of the proposed trial?

  1. Legitimate telecommunications that are unduly blocked, either intentionally or inadvertently as a result of Bell Canada et al.’s call-blocking system, constitute false positives for the purposes of this decision.

Positions of parties

  1. Several interveners raised concerns regarding the potential for false positives and the disruption of legitimate telecommunications by the proposed trial. TCI submitted that while it supported Bell Canada et al.’s application generally, it must be acknowledged that some false positive results will occur, and that this must be balanced against the potential good that the companies’ system may achieve. TCI added that calls to 9-1-1 should not be blocked under any circumstances.
  2. Mr. Nanni submitted that, given Bell Canada et al.’s estimate of the volume of fraudulent or scam calls currently transiting their networks, false positives may range in the thousands, based on his estimated 0.2% false positive rate.
  3. Allstream and Iristel raised concerns that redress measures may not be clear to consumers whose telecommunications are affected as a result of a false positive, and that any such redress must be quickly and easily accessible.
  4. RCCI argued that requiring TSPs to proactively request that telecommunications be unblocked would be cumbersome, particularly in the case of false positives resulting from the provision of previously unassigned numbers that have been blocked by Bell Canada et al. It submitted that an automated approach would mitigate any such burden on third parties.
  5. Bell Canada et al. disputed Mr. Nanni’s estimate of the potential number of false positives that may occur as a result of their trial. They added that certain classes of calls would not be blocked under any circumstances.
  6. Bell Canada et al. submitted that although they do not foresee any false positives occurring, they would implement certain preventative and redress measures to address interveners’ concerns. They committed to implementing an automated unblocking process that would provide TSPs with a contact number to report possible false positives and to expeditiously investigate any reported false positives. They also committed to promptly implement changes to avoid similar false positives.

Commission’s analysis and determinations

  1. The Commission acknowledges Bell Canada et al.’s submission that they do not expect false positives, given the extensive and thorough verification system they have developed. The Commission accepts that false positives are unlikely given the design of the system; however, it also considers that the possibility of false positives should not be ruled out.
  2. Given the minimal false positives, if any, that can be expected to result during Bell Canada et al.’s proposed trial, the Commission considers that the risks associated with false positives are not significant. The Commission therefore concludes that any such risks can be adequately addressed by ensuring that Bell Canada et al. respond to complaints about blocked calls in an appropriate manner, and by requiring Bell Canada et al to implement their suggested unblocking mechanism. This would require Bell Canada et al. to implement efficient and effective procedures to deal with complaints concerning blocked calls, combined with rigorous redress mechanisms to resolve any false positives fairly, swiftly, and comprehensively. These procedures and redress mechanisms would ensure that repeated false positive events do not occur. 

How is the data used or generated by Bell Canada et al. during the proposed trial to be handled?

Positions of parties

  1. Several interveners, including Allstream, the ISCC, Dr. McKelvey and Dr. Rajabiun, and Mr. Nanni, raised a number of concerns regarding the data that Bell Canada et al. may collect or use to operate their call-blocking system. These concerns touched on possible competitive or commercial uses for this data that the companies may attempt to exploit, as well as the protection of consumer data and privacy.
  2. The ISCC, Dr. McKelvey and Dr. Rajabiun, and Mr. Nanni also expressed concern as to the nature of the data collected insofar as it may allow the identification or targeting of specific persons.
  3. Bell Canada et al. submitted that by design, their AI system would be unable to target a specific individual or TSP because it does not operate on a level that can access or query the information required to facilitate such activity. According to Bell Canada et al., any accumulated data would be anonymized to ensure individual privacy.
  4. Bell Canada et al. added that they are committed to implementing data safeguards to protect the collection, use, disclosure, retention, and destruction of data in relation to the trial. They outlined the various measures already in place to protect consumer data and emphasized the various data and privacy obligations to which they are already subject.

Commission’s analysis and determinations

  1. The Commission notes that the data that Bell Canada et al. will use for their proposed call-blocking trial is obtained and retained by Bell Canada et al., like all other TSPs, as a matter of course to provide telecommunications services and operate telecommunications infrastructure. Nevertheless, the Commission recognizes that the proposed trial involves a novel use of that data and requires its manipulation to provide input for the call-blocking system for the purposes of flagging, verifying, and blocking of fraudulent and scam calls in Bell Canada et al.’s networks. The Commission notes that Bell Canada et al.’s regulatory and other legal obligations regarding the collection, use, and disclosure of personal and other confidential information will apply to Bell Canada et al.’s collection, use, and disclosure of any such information for the purpose of their proposed call blocking system. Given the novel manner in which the information would be used in order to detect fraudulent and scam calls, the Commission considers that Bell Canada et al. should not be permitted to use or disclose such information for any purpose other than for the purpose of implementing the trial of the call-blocking system approved in this decision. Subject to the foregoing, the Commission is satisfied that the measures in place for the protection of confidential information, along with the consent requirements for the collection, use, and disclosure of personal information, and other measures to safeguard the privacy of individuals, are sufficient.

Conclusion

  1. In light of all the above, the Commission considers that the concerns raised by interveners, individually and collectively, do not justify denying the call-blocking trial proposal and depriving consumers of the protection from harm resulting from verified fraudulent and scam calls. The Commission notes the rigorous methodology proposed by Bell Canada et al. to identify and verify fraudulent and scam calls and the fact that the approval sought in this application is solely for a 90-day trial.  Extending the trial, or implementing the call-blocking system on a permanent basis will require further process and Commission approval. The Commission therefore finds that with the appropriate oversight and measures to mitigate the impact of unintended or inadvertent blocking of legitimate calls, the benefits of Bell Canada et al.’s proposed trial outweigh the risks discussed by interveners.
  2. Accordingly, the Commission concludes that approval of Bell Canada et al.’s application, pursuant to section 36 of the Act and subject to the additional measures and requirements set out below, would be in the public interest and in furtherance of the telecommunications policy objectives set out in paragraphs 7(a), (b), (c), (h), and (i) of the Act,Footnote 10 and would be consistent with the 2006 Policy Direction and the 2019 Policy Direction.
  3. The Commission therefore approves Bell Canada et al.’s application to temporarily block certain known and verified fraudulent and scam voice calls on a 90-day trial basis, as set out in their application, subject to the conditions set out below. The Commission notes that certain conditions refer to information that Bell Canada et al. submitted in confidence. Consistent with its determinations in Compliance and Enforcement and Telecom Decision 2020-7, the Commission finds that disclosing certain aspects of the call-blocking system may provide a material advantage to those who would seek to evade it, and concludes that the harm likely to result from disclosure on the public record of such details outweighs the public interest in disclosure. Accordingly, the Commission has retained in confidence certain details in the conditions set out below that would reveal confidential information concerning Bell Canada et al.’s call-blocking system. These details are set out in a separate letter to Bell Canada et al. (hereafter, the confidential letter) and disclosed to those interveners who signed an NDA pursuant to the process set out in Compliance and Enforcement and Telecom Decision 2020-7. 
  4. The conditions of approval are as follows:
    1. Bell Canada et al. shall file, on a monthly basis for the duration of the trial, a report containing the total number and frequency of blocked calls each week, in the manner specified in the confidential letter, including the date(s) on which the calls were blocked and where such calls entered Bell Canada et al.’s networks, to the extent such information is known. The reports are due 15 days after the end of each 30-day period of the trial.  
    2. With regard to false positives,
      1. Prior to the start of the trial, Bell Canada et al. shall
        1. establish and maintain, for the duration of the trial, a telephone number and email address for TSPs to submit to Bell Canada et al. complaints or notices about possible false positives; and
        2. notify TSPs offering voice communications services of the telephone number and email address for TSPs to submit complaints or notices of possible false positives. This notification must inform the TSPs of the service standard outlined in item b) below.
      2. Bell Canada et al. shall maintain a 24-hour turnaround time from the time they are first notified of a potential false positive, either by a TSP or otherwise, to the resolution of the false positive. 
      3. Within the mandated 24-hour service standard, Bell Canada et al. shall file with the Commission, and provide to a complainant TSP, a report containing all supporting evidence used to reach their determination(s) on whether a false positive occurred, including the information specified in the confidential letter. Any deviations from this service standard are to be immediately reported to the Commission, along with justification.
      4. Where Bell Canada et al. has become aware of a false positive, other than by way of a complaint, they shall file with the Commission, within 24 hours of becoming aware of the matter, a report containing the details of remediation mechanisms on a per-incident basis.
      5. Bell Canada et al. shall unblock any and all telecommunications blocked as a result of a false positive as soon as they confirm such a result. This unblocking must occur within the mandated 24-hour service standard.
      6. Bell Canada et al. shall implement certain unblocking measures, as specified in the confidential letter.
    3. Bell Canada et al. shall file, for each 30-day period during the trial, a report containing the number of false positives per total calls blocked each week, an explanation as to how these false positives were detected and why the false positives occurred, and complete details of the measures taken to prevent the reoccurrence of similar instances and such other information regarding the unblocking of calls as specified in the confidential letter. The reports are due 15 days after the end of each 30-day period of the trial.
    4. Bell Canada et al. shall file, within 30 days of the completion of the trial, a final report of the trial and its outcomes, including an analysis of the efficacy of the call-blocking system and a summary of the aforementioned reports and data.
    5. Bell Canada et al. shall not use or disclose any personal or otherwise confidential information used to detect fraudulent and scam calls for any purpose other than for the purpose of implementing the trial of the call-blocking system approved in this decision.
    6. Upon request by the Commission, Bell Canada et al. shall provide any additional data or reports in relation to this trial, within such time frame as may be determined by the Commission.

Secretary General

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