Telecom Commission letter addressed to the Distribution List
Ottawa, 24 August 2020
Our reference: 8665-C12-202000280
RE: Unauthorized Mobile Telephone Number Transfers and SIM Swapping in Canada – Request for Immediate Action Directing the Members of the CWTA WNP Council to Delay the Roll-out of the Enhanced Process Regarding Fraudulent Mobile Number Porting
This letter is further to the Canadian Wireless Telecommunications Association’s (CWTA) letter of 12 August 2020 regarding the rollback of the implementation of the enhanced mobile number porting process (the Enhanced Process). By letter dated 20 August 2020, Quebecor Media Inc., on behalf of its affiliate Videotron Ltd., (Videotron) and Shaw Communications Inc. (Shaw) requested that the Commission take immediate action directing the members of the CWTA Wireless Number Portability (WNP) Council to refrain from introducing or reintroducing any measures to block fraudulent mobile number porting until the Commission has had the opportunity to review the efficacy of such measures.
Videotron and Shaw stated that the problems encountered during the week in which the Enhanced Process was in effect are complex, as are the potential remedies for resolving them. Accordingly, in its 12 August 2020 letter, CWTA committed to update the CRTC on the status of the work to resolve the issues and the estimated restoration date. The CWTA indicated that it would likely be able to provide such an update within two weeks of its letter (i.e. by 26 August 2020).
Videotron and Shaw stated that, rather than wait for a coordinated response from the industry, one incumbent member of the WNP Council has declared that the procedures it implemented on 5 August 2020 require no modification and that it will be reactivating its version of the Enhanced Process on 26 August 2020. Further, two other members of the WNP Council have reacted by announcing that they may be compelled to take similar action to protect their commercial interests.
Videotron and Shaw submitted that if any member of the WNP Council is permitted to proceed with the relaunch of the Enhanced Process on 26 August 2020, the harm to Canadian consumers will be substantial. They noted that data collected during the week in which the Enhanced Process was in effect reveal that, for certain carriers, 40 - 50% of attempted mobile number ports resulted in failure. Videotron and Shaw argued that this rate of failure for legitimate number ports is unacceptable.
Videotron and Shaw submitted that blocking fraudulent mobile number porting is an important policy objective but that achieving this objective should not come at the cost of a large-scale frustration of the legitimate customer transfer process.
By letter dated 22 August 2020, Bell Mobility Inc. (Bell) and TELUS Communications Inc. (TELUS) supported the request by Videotron and Shaw. Bell Mobility and TELUS stated that their objective has been and continues to be the implementation of an Enhanced Process that maintains, to the maximum extent possible, ease of porting for consumers.
Bell and TELUS added that addressing the issues the WNP Council has identified, which include implementing a more consistent consumer experience, simply requires more time and the co-operation of all WNP Council members. In their view, the premature re-introduction by any member of the WNP Council of the Enhanced Process without a co-ordinated effort is not in the best interest of consumers. They stated that they are committed to working towards a deadline of 15 October 2020 to reintroduce the Enhanced Process, modified on an industry-wide basis, to address its impact on valid number ports and with a more consistent consumer experience.
By letter dated 24 August 2020, Rogers Communications Canada Inc. (Rogers) stated that the WNP Council’s efforts to resolve the issues as between the members is at an impasse. The issues that are at the centre of the impasse; Rogers identified the issues as follows:
- a) appropriate training and awareness of frontline teams to make porting customers aware of what is required of them to authorize the port as legitimate is required;
- b) consensus must be reached about who is authorized to confirm a port i.e., the Account Holder who is responsible for the Account or the Device Holder who is NOT responsible for the Account; and
- c) the best way of ensuring that the method by which the confirmation activity is addressed to the customer also acts to minimize or eliminate the ability of a fraudster to spoof the authorization is minimized or eliminated.
Rogers stated that it should be entitled to relaunch its Enhanced Process on 26 August 2020 and requested that Commission staff closely monitor the WNP Council activities in the meantime to provide guidance on the matters of non-consensus noted above in order to allow other Council Members to meet the Bell and Telus proposed 15 October 2020 target date some seven weeks from now.
Commission staff has concerns that if the problems encountered during the week in which the Enhanced Process had been rolled out are not properly understood, assessed and resolved before a relaunch of the Enhanced Process on 26 August 2020, there will likely be substantial harm to Canadian consumers and the industry.
Regardless of the implementation date, Commission staff has concerns that the roll-out of the Enhanced Process without industry coordination on the implementation of the various steps required could result in a high failure rate of attempted mobile number ports for legitimate number ports. This is not in the best interests of Canadian consumers.
Blocking fraudulent mobile number porting is important for the protection of Canadian consumers; however, to achieve this objective, it is imperative that the selected process does not result in large-scale frustration of the legitimate customer transfer process.
In view of this, Commission staff requests that the CWTA, the WNP Council members included in the distribution and any interested party address the following questions and file submission by 25 August 2020, serving their responses to all persons copied on this letter:
- Would a 15 October 2020 deadline for the relaunch of the Enhanced Process, modified on an industry-wide basis, be reasonable and appropriate? If not, propose an alternative date with supporting evidence and rationale. Note that achieving this deadline implies all members of the WNP Council under the auspices of the CWTA have collectively addressed the issues identified with the Enhanced Process.
- In their 20 August 2020 letter, Shaw and Videotron request that the Commission review the efficacy of any new measures to be adopted with a view to blocking fraudulent porting request whereas Bell and TELUS argue that no such Commission involvement is needed, having regard to the Commission will be updated on the status of work surrounding these matters. Provide your views as to whether the Commission ought to require that any enhanced porting verification measures be approved by the Commission prior to being implemented?”
- Would it be reasonable and appropriate for Commission staff to participate as observers during WNP Council discussions on the Enhanced Process? If not, explain why.
Members of the WNP Council are requested to refrain from introducing or relaunching any measures to block fraudulent mobile number transfers until such time as responses to the question above have been provided and reviewed. Each member of the WNP Council is to provide written confirmation to Commission staff, by 25 August 2020, that they will not re-launch the Enhanced Process until further notice.
Furthermore, the CWTA and the WNP Council members included in the distribution list are requested to file by 28 August 2020 the following information as it relates to the time during which their respective enhanced verification procedures had been implemented prior to their suspension :
- Specify the dates during which the Enhanced Process was active.
- How many number transfer requests:
- were received;
- did not proceed;
- did proceed and the proportion (in percentage and absolute numbers) of these processed ports that were completed within the Commission-established number transfer timeframes.
- What were the different reasons for number transfer requests not proceeding and the prevalence (in percentage and absolute numbers) associated with every identified reason.
- How does the number of number transfer requests that did not successfully proceed compare with numbers associated with the period prior to implementation of the enhanced verification process.
- Quantify the impact that these measures had on curbing illegitimate number transfer requests.
All question requested herein, are in addition to the Commission 20 August 2020 Request for Information Letter. Further, note that a copy of the current letter will be made public.
Original signed by Étienne Robelin for
Director, Dispute Resolution & Regulatory Implementation
c.c.: Ursula Grant, CWTA, firstname.lastname@example.org
John Lawford, PIAC, email@example.com
Eric Smith, CWTA, firstname.lastname@example.org
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