Telecom - Commission letter addressed to Aladin Pierre Gaston (Flexexports Inc.)

Ottawa, 23 April 2021

Our reference:  8160-F92-202102440

BY EMAIL

Aladin Pierre Gaston
Flexexports Inc.
391 Avenue Yvon Berger,
Laval, QC H7L 2B9
agaston@flexgroups.com

Re: Registration of Flexexports Inc. as a proposed full MVNO

Aladin Pierre Gaston,

On 21 April 2021, Flexexports Inc. (FlexTelecom) requested to be registered as a proposed full Mobile Virtual Network Operator (MVNO). Based on the information provided, and in particular the statement by FlexTelecom’s that it intends to meet the eligibility requirement for a full MVNO within 12 months of the registration date, FlexTelecom has been placed on the list of proposed full MVNOs, in accordance with the Telecom Decision CRTC 2015-496.

FlexTelecom is reminded that, as per the Commission’s policy set out in Telecom Decision CRTC 2015-496, within 12 months of the date of registration as a proposed full MVNO, FlexTelecom must clearly demonstrate to the CRTC that it meets the technical criteria of a full MVNO, as described in the Canadian International Mobile Subscriber Identity (IMSI) Guideline.

In addition, FlexTelecom must demonstrate that it has concluded a wholesale full MVNO access agreement with a Canadian wireless carrierFootnote1. Failure to clearly demonstrate to the Commission that it has met the criteria of a full MVNO, as per the IMSI Guideline by 23 April 2022, will result in removal of FlexTelecom from the CRTC’s proposed full MVNO registration list.

In order to ensure that Commission staff has sufficient time to review a request to be registered as a full MVNO and determine that the criteria have been met before this date, FlexTelecom is required to request this registration and file all the necessary information by 08 April 2022. Instructions on how to request to be registered as a full MVNO is attached in Appendix A.

FlexTelecom is reminded that, depending on the telecommunications services it intends to provide, it may be required to register on additional lists or obtain a BITS licence. In order to determine this, Commission staff will be in communication with FlexTelecom to provide the necessary advice and guidance.

FlexTelecom is reminded that in order to remain on any of the Commission’s telecommunications’ registration lists it must comply with the appropriate regulatory regime, and submit the required information via the Commission’s Data Collection System (DCS), on an annual basis.  Failure to comply with the DCS requirements will result in the removal of FlexTelecom from all CRTC registration lists. As per Telecom Regulatory Policy 2019-354, entities removed from any registration list will be placed on the list of withdrawn telecommunications provider registrations published on the Commission’s website.

Yours sincerely,

Original signed by

Mark Allen
Senior Manager – Market Intelligence

c.c.:      Garth Steele, Central Fund Administrator
J.R. Sarrazin, President of the Canadian LNP Consortium Inc.
Julia Kennedy, secrétaire du Consortium de gestion du Fonds central
Edward Antecol, Canadian Numbering Administrator
Gary Jessop, Canadian Numbering Consortium Inc.

APPENDIX A

Registration requirements for a full MVNO

Within 12 months of being registered as a proposed full MVNO the entity must clearly demonstrate to the Commission that it has met the requirements to be registered as a full MVNO as per the International Mobile Subscriber Identity (IMSI) Guideline.

According to the IMSI Guideline, a full MVNO is an entity that meets these eligibility requirements:

  1. Clearly demonstrates in writing that it meets the technical criteria of a full MVNO.  This includes providing a network diagram and description that demonstrates that it:
    1. owns and operates core network hardware separate from all wireless service providers (WSPs);
    2. has a service profile management system (SPMS) for end-user devices that can access WSP networks in Canada
      • The descriptions should include how the entity’s network operates and how it accesses its host wireless carrier’s network.
  2. Identifies the wireless carrier with whom the entity has a wholesale full MVNO access agreement.  The entity must provide a contact name of an individual at its host wireless carrier who can address questions regarding the technical nature of the wholesale full MVNO access agreement.

In order to ensure that Commission staff has sufficient time to review a request to be registered as a full MVNO and determine that the criteria have been met, entities should, two weeks before the registration expiry date, submit the above information and any information it deems relevant to its application, by a letter addressed to the Secretary General.

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