CLHIA comments re: Compliance and Enforcement Notice of Consultation CRTC 2013-527Release Date: 10/30/2013 Staff Reference: Peter Goldthorpe
October 30, 2013
Canadian Radio-television and Telecommunications Commission
RE: Compliance and Enforcement Notice of Consultation CRTC 2013-527
1. Established in 1894, the Canadian Life and Health Insurance Association (CLHIA) is a voluntary trade association that represents the collective interests of its member life and health insurers which, together, account for 99% of the life and health insurance in force in Canada. Our members contribute to the financial well-being of millions of Canadians by providing a wide range of financial security products, including over $3.8 trillion of life insurance coverage. The industry has more than $522 billion invested in Canada's economy and provides employment directly to about 139,000 Canadians.
2. The Commission asks whether the registration of telecommunications numbers by Canadians on the National Do Not Call List (DNCL) should be made permanent.
3. The Commission notes that this matter was reviewed in the 2006 consultations on the establishment of the National DNCL framework and again in 2008 when the specific question of making registration permanent was revisited. On both these occasions, the Commission's decision to limit registration to a finite period reflected the need to balance competing interests. On one hand, individuals who do not wish to receive telemarketing calls want the convenience of permanently registering their number on the National DNCL. On the other hand, telemarketers who are funding the registry through their subscription fees should not be asked to fund a system that arbitrarily limits legitimate telemarketing due to the fact that the registry is populated with numbers that should not be on it.
4. Research conducted for the CRTC has concluded that an efficient and cost-effective means of removing disconnected and reassigned numbers from the National DNCL is not available in Canada.
5. In light of this conclusion, CLHIA submits that the relevant facts remain unchanged from those that informed the 2006 and 2008 consultations. CLHIA further submits that the reasoning of the Commission was sound and that the compromise it struck in setting a finite registration period produced a fair outcome for all parties.
6. Last year, the Commission signalled its intention to maintain subscription rates for the National DNCL at current levels. It is worth noting, therefore, that the current proposal to leave numbers on the National DNCL for an indefinite period will have the effect of imposing additional costs on telemarketers. In its report to the Commission, the Business Practices Working Group noted that permanent registration without automatic removal of disconnected and reassigned numbers would, over time, result in the National DNCL being contaminated with disconnected and reassigned numbers. Some portion of these numbers can reasonably be expected to be assigned to individuals who might not wish to have their number on the National DNCL and may be amenable to learning about products and services through telemarketing. By giving rise to lost economic opportunity, permanent registration imposes an additional cost on telemarketers who fund the National DNCL.
7. For these reasons, in the interests of fairness, CLHIA submits that the requirement to re-register a number on the National DNCL after a finite period should be retained.
(Original signed by)
Peter B. Goldthorpe
Director, Marketplace Regulation Issues