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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 23 July 2024

Our reference: 1011-NOC2016-0293, 1011-NOC2018-0422

BY EMAIL

Distribution List

Subject: Request for information on current practices related to changes to the Telecommunications Act stemming from Budget 2024 – Prohibition of fees for the activation or modification of a service plan

Service Provider,

Bill C-69, An Act to implement certain provisions of the budget tabled in Parliament on April 16, 2024,Footnote1 was assented to on 20 June 2024. Division 37 of the Bill relates to changes to the Telecommunications Act seeking to impose further consumer protection measures on telecommunication service providers (TSPs).

One of these consumer protection measures is a prohibition on TSPs charging a fee to a subscriber that is related to the activation or modification of a telecommunications service plan.

Responses to the questions contained in the appendix to this letter are to be filed with the CRTC using GCKey by no later than 23 August 2024. Companies that operate flanker brandsFootnote2 must file responses on behalf of these brands in addition to their primary brands.Footnote3

As set out in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin 2010-961, 23 December 2010, as amended, TSPs may designate certain information as confidential.

TSPs must provide an abridged version of the document involved, accompanied by 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.

Responses to this request for information will be added to the record of any relevant proceeding the CRTC may launch.

If you have any questions, please contact Guillaume Leclerc, Senior Policy Analyst, Social and Consumer Policy, at Guillaume.leclerc@crtc.gc.ca.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy

Distribution List

bell.regulatory@bell.ca;  
geoff@brooketel.ca;   
Regulatory@brucetelecom.com;   
telecom.regulatory@cogeco.com;  
Regulatory.Matters@corp.eastlink.ca;  
regulatory@corp.wightman.ca;  
Xplornet.Legal@corp.xplornet.com;  
martha.facey@execulink.com;   
a.lawrence@hay.net;   
ryan.mcclinchey@hurontel.on.ca;   
regulatory@icewireless.com;  
regulatory@iristel.com;   
knaylor@mornington.ca;   
lhallahan@mornington.ca;  
regulatoryaffairs@nwtel.ca;  
regulatory@quadro.net;   
regaffairs@quebecor.com;  
melanie.cardin@quebecor.com;  
rwi_gr@rci.rogers.com;  
ruth.altman@rci.rogers.com;  
document.control@sasktel.com;   
regulatory@sjrb.ca;  
richard.biron@sogetel.com;   
stephen.scofich@tbaytel.com;   
regulatory@tccmail.ca;   
reglementa@telebec.com;  
regulatory.affairs@telus.com;   
harleen.sawhney@zoomermedia.ca;  
scott_laird@ztarmobile.com;

Appendix 1: Questions to be answered by TSPs

The Telecommunications Act has been amended add the following: 

  1. 27.04 (1) A telecommunications service provider must not charge a fee to a subscriber that is related to the activation or modification of a telecommunications service plan, or any other fee whose main purpose is, in the opinion of the Commission, to discourage subscribers from modifying their service plan or cancelling their contract for telecommunications services.
  2. (2) The Commission must specify the types of fees for the purposes of subsection (1).

With that context in mind, provide responses to the following questions: 

  1. List all currently assessed fees that could be considered a discouragement for subscribers from modifying or cancelling their telecommunications service plan,Footnote4 and for each, detail (broken out by service type, e.g. mobile wireless services, Internet access services, home telephony services):
    1. The rationale for the fee
    2. When the fee may be charged
    3. The amount of the fee, or the possible range
    4. How subscribers can avoid the fee, if at all
    5. Over the last 5 years (broken out by year),
      1. How often the fee was assessed,
      2. The total amount of revenues the fee represents
      3. Total Revenues earned from the service type
      4. Total number of subscribers of that service type that were charged the fee
      5. Total number of subscribers of that service type?
      6. What is the forecast retention of retail subscribers of that service type?
    6. For each fee, respond to the following questions in a scenario where you were required to no longer charge the fee: 
      1. How would not charging the fee change your processes or procedures?
      2. How long do you anticipate to roll out any changes to your processes or procedures?
      3. The total short, medium and longer-term (e.g. maintenance) costs associated with making any changes to your processes or procedures and how the longer-term costs would compare to those costs before the change?
      4. The potential impact on subscribers’ monthly cost.
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