Telecom - Secretary General Letter addressed to Justin Gerogiannis (Eastlink)

Ottawa-Gatineau, 13 February 2025

Reference: 8621-C12-01/08

BY EMAIL

Justin Gerogiannis
Chair, Canadian Radio-television and Telecommunications Commission Interconnection Steering Committee Business Process Working Group
Eastlink
6080, Young Street
Halifax, Nova-Scotia B3K 5L2
Justin.Gerogiannis@corp.eastlink.ca

Subject: Proposed changes to porting verification processes – request for ex parte treatment of the Report and associated documents

Dear Justin Gerogiannis,

We are following up on the Canadian Radio-television and Telecommunications Commission (CRTC) Interconnection Steering Committee’s (CISC) Business Process Working Group (BPWG) consensus Task Identification Form Report BPRE104A, updated Canadian Local Ordering Guidelines (C-LOG), and associated documents (collectively, the documents).

By way of a Commission staff letter dated 14 September 2022, the BPWG was asked to consider what additional measures could be put in place to prevent unauthorized customer transfers from landline/wireline carriers to other carriers (fraudulent porting) and to file a report outlining its recommendations with the Commission.

In filing the documents with the Commission, the BPWG designated certain information as confidential pursuant to Section 39 of the Telecommunications Act (the Act) and the Procedures for filing confidential information and requesting its disclosure in Commission proceedings. This included information about the measures the BPWG considered to prevent fraudulent porting and which of these measures it recommended the Commission impose as obligations on all telecommunications service providers (TSPs).

According to the BPWG, this information is highly sensitive, and knowledge that a measure has been recommended could result in fraudsters circumventing a future fraud mitigation measure imposed by the Commission. As a result, while the BPWG filed both confidential and redacted versions of the documents with the Commission, it requested ex parte^Footnote1 treatment of the documents. In particular, it asked that no one other than the Commission and the BWPG and its members be made aware that the documents had been filed or that the Commission had imposed obligations on all TSPs, until after the proposed measure to prevent fraudulent porting is implemented.

The Commission is an administrative tribunal committed to transparency and procedural fairness. The Commission is of the view that the public interest in allowing interested persons, including those who would be subject to the obligation under consideration, to comment on this matter outweighs any potential harm in making public the proposed measure to combat fraudulent porting.

Considering the above, the Commission denies the BPWG’s request for ex parte treatment of the documents. The Commission requests that the BPWG submit a revised redacted version of the documents for posting on CISC’s website with a view to disclosing sufficient information to allow interested persons to meaningfully comment. Specifically, the BPWG is asked to identify, at a minimum, the proposed validation measure, the criteria used to assess the measures considered, and the resulting changes to the C-LOG. This information is to be filed by March 5, 2025.

Interested persons can file comments on the redacted version of the documents until April 4, 2025. Please ensure that any remaining claims for confidentiality are made in accordance with the requirements set out in the CRTC Rules of Practice and Procedure. The Commission notes that CISC working group documents and reports are generally publicly available, and that participation in CISC working groups is typically open to any interested person. TSPs who wish to have more information on this issue can become a member of the BPWG’s Task Identification Form working group, which is comprised of industry players who have a direct interest in this issue.

All documents must be received by the dates indicated above and can be filed on the Commission’s website using GCKey.

Any questions pertaining to this letter may be directed to Christine Brock, Manager, Telecommunications, at christine.brock@crtc.gc.ca.

Sincerely,

Original signed by

Marc Morin
Secretary General

C.c.:   Michel Murray, Director, Telecommunications, CRTC, michel.murray@crtc.gc.ca
Christine Brock, Manager, Telecommunications, CRTC, christine.brock@crtc.gc.ca

Date modified:

2025-05-13