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Telecom - Staff Letter addressed to Bryan Cohen (Opn Communication Canada Corp)

Ottawa, 20 June 2024

Reference: 8160-O138-202403203
Registration Date: 20 June 2024
Expiry of Registration: 20 June 2025

BY E-MAIL

Bryan Cohen
Opn Communication Canada Corp
209 W. 242nd St
Bronx, AB 10471

bcohen@opncomm.com

Subject: Registration of Opn Communication Canada Corp as a proposed full MVNO

Dear Bryan Cohen:

On 01 April 2024, Opn Communication Canada Corp requested to be registered as a proposed full Mobile Virtual Network Operator (MVNO). Based on the information provided, and in particular the statement by Opn Communication Canada Corp’s that it intends to meet the eligibility requirement for a full MVNO within 12 months of the registration date, Opn Communication Canada Corp has been placed on the list of proposed full MVNOs, in accordance with the Telecom Decision CRTC 2015-496.

Opn Communication Canada Corp 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, Opn Communication Canada Corp 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, Opn Communication Canada Corp 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 20 June 2025, will result in removal of Opn Communication Canada Corp 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, Opn Communication Canada Corp is required to request this registration and file all the necessary information by 06 June 2025. Instructions on how to request to be registered as a full MVNO is attached in Appendix A.

Opn Communication Canada Corp 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 Opn Communication Canada Corp to provide the necessary advice and guidance.

 

Opn Communication Canada Corp 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 Opn Communication Canada Corp 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.:      Bryden McMaster, Central Fund Administrator
J.R. Sarrazin, President of the Canadian LNP Consortium Inc.
Julia Kennedy, Secretary of the Central Fund Administration Consortium
Kelly T. Walsh, 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.

  1. 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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