Industry Committee on March 10th, 2020

[Ian Scott]

We are exploring some of those things. We have an application for a trial using such an application of artificial intelligence in front of us right now.

[The Chair, Liberal, Sherry Romanado]

Thank you.

The last round of questions for five minutes starts with Madam Lambropoulos.

[Emmanuella Lambropoulos, Liberal, Saint-Laurent, QC]

Thank you.

I'd like to thank both the CRTC and the RCMP for being here to answer our questions. I'll try to be as brief as possible.

I've had quite a few constituents of mine complain to my office about the fraud that they've fallen victim to. Some of them have lost all of their retirement savings and are in debt at this point because of these calls. When they come, they've completely lost all hope because they've already gone to the police, and the police have basically told them there's nothing they can do.

Could you maybe give us some insight as to what process is actually gone through once people have made a complaint and whether it's possible ever to identify where these calls are actually being made from, whether they're international? Do we find the location of these callers?

[A/Commr Eric Slinn]

Sure. First and foremost, again, law enforcement needs to do a better job. A lot of the times you're quite right in that they take a call from a complainant who's been victimized, lost some money. What they're hearing sometimes from law enforcement, RCMP included, is they should call the Canadian Anti-Fraud Centre. That's not the correct thing to do. That's one step to do. The Canadian Anti-Fraud Centre is not an investigative body. It collects intelligence, trends and so on.

When a complaint comes, what they should do is take the complaint, take as much information as possible and then work an investigation like any other investigation, working backwards, with ISPs, getting the phone numbers. Some police officers will say it's a difficult charge to prove because oftentimes these are call centres in India or elsewhere in the world. There are extradition challenges. All these are investigative challenges, but from an RCMP perspective where we are responsible for transnational organized crime, we do have the reach that we can do it.

We can't solve every complainant's victimization, but we can let them know that their complaint is important, it's received and we will do what we can. Sometimes it's merely the intelligence that we can take, and then we find out that it is a specific call centre, as Mr. David Common did in some great work on CBC once.

That's essentially what is supposed to happen, but improvements are needed within the broader law enforcement community in how we handle these complaints.

[Ian Scott]

I would add very briefly that we also, collectively, need to do a better job to prepare consumers to defend themselves, to educate consumers. You shouldn't be pressed to respond instantly. You should think carefully about why someone is asking you to respond or give your data instantly, and then think about other ways of going back to your bank or whomever to verify. Canadians need to protect themselves against fraud, and it behooves us to better prepare them to do so.

[Emmanuella Lambropoulos, Liberal, Saint-Laurent, QC]

Of course, prevention is key, and that would be the best-case scenario, but in cases where it actually does happen, and obviously it happens quite often....

As you mentioned earlier, it happens more internationally; it's more of a global problem. You did mention that you're working with several countries around the world to help solve these issues. Is there opportunity for more collaboration with more countries so that when you do find out that it's coming from a call centre in India, it's actually punishable, and the criminals can be charged?

[A/Commr Eric Slinn]

We do the best we can. We work with the Five Eyes Law Enforcement Group. We work quite well with U.S. agencies that have quite a broad reach. In the case of India, we have worked with the Indian authorities in a couple of cases. However, we're at their whim because the RCMP has no authority in a foreign country, so we have to work with them and encourage them that this is important to our citizens, encourage them to please take action on this. They have other priorities of their own, so it poses a significant challenge.

I think that, at the political level, we need pressure from government to government to say, “You're affecting our people.” The RCMP, the CRTC and others can do our best, but we can only work within our authorities, and we don't have authorities extraterritorially, with the exception of a few offences.

[Emmanuella Lambropoulos, Liberal, Saint-Laurent, QC]

Thank you very much.

That's it for me, but I'm going to pass my time to my colleague, Ms. Dabrusin.

[The Chair, Liberal, Sherry Romanado]

You literally have 40 seconds.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

Okay.

I want to pick up on what Mr. Patzer was asking before about email scams and texting scams. In my community, that's where I actually see the most action.

You talked briefly about numbers. I'm almost out of time, so what I would ask is whether there is any information you can provide—maybe links to your websites—about what you're doing to inform Canadians and how we can better inform Canadians to protect themselves from those scams because that's where I see the most activity when I talk to people.

[A/Commr Eric Slinn]

The CAFC is probably your best resource. We update on new scams and what can be done. There are senior support people to call back. The CAFC is one, and the other would be the RCMP site. However, CAFC is where people should go for information.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

If you could actually send it to the committee if there is—

[A/Commr Eric Slinn]

I will do that.

[Julie Dabrusin, Liberal, Toronto—Danforth, ON]

Thank you.

[The Chair, Liberal, Sherry Romanado]

Thank you very much.

Unfortunately, that's all the time we have for this panel.

I would like to thank all of you for being here.

With that, we will suspend momentarily to allow the next panel to arrive.

Thank you.

[The Chair, Liberal, Sherry Romanado]

I would like to welcome you back for the second panel at the Standing Committee on Industry, Science and Technology

as part of our study on fraud calls in Canada.

Joining us now from Bell Canada, we have Jonathan Daniels, vice-president of regulatory law, and from Rogers Communications, Howard Slawner, vice-president of regulatory affairs, and Deborah Evans, chief privacy officer.

From TELUS communications, we have Jérôme Birot, vice-president of development operations, and John MacKenzie, director of regulatory affairs.

Ladies and gentlemen, because we have three groups with us today, we'll ask that your presentation be eight minutes in length, and at that point we will be going to the round of questions.

When you see the yellow card, it means you have 30 seconds left to finish your presentation.

With that we will start with Bell Canada. Mr. Daniels, you have eight minutes.

[Jonathan Daniels, Vice-President, Regulatory Law, Bell Canada]

Good afternoon, Madam Chair.

My name is Jonathan Daniels. I am Bell Canada's vice-president of regulatory law.

It is my pleasure to be here today to share with you the steps we have taken and continue to take in an effort to combat nuisance and fraudulent calling. We are strong proponents of protecting Canadians against these types of calls.

Specifically, I will speak to the three issues you asked us to discuss in this invitation: the national do-not-call list; fraudulent and nuisance calls; and STIR/SHAKEN protocols.

To begin, I'd like to address the issue of the national do-not-call list. While we agree that the list is a good tool that can help reduce the number of telemarketing calls received by Canadians and we are glad to have the benefit of such a tool in Canada, this tool does have limitations. Specifically, the national do-not-call list is only effective if everyone adheres to it. Unfortunately, the vast majority of nuisance calls received by Canadians come from callers outside of Canada that do not adhere to the national do-not-call list. Thus, we have to continually come up with new ways to stop unwanted calls.

This brings me to the issue of the recent influx of nuisance and fraudulent calls being experienced by Canadians. It is important to note that there is a difference between nuisance calls and fraudulent calls. Nuisance calls are calls that you do not want to receive. These types of calls are generally trying to sell you a service, such as duct cleaning. They are a nuisance and likely unwanted, but they are not necessarily illegitimate or fraudulent. Fraudulent calls are much worse than nuisance calls, as they are specifically designed to defraud Canadians. For example, you may receive a call offering to fix your computer, which is really an attempt to install a virus and lock you out of your computer, leading to a ransom demand. Other scams relate to credit cards. I have lost count of the number of times I have received a call from the so-called Visa/Mastercard centre, not to mention the infamous CRA scam. These fraudsters are sophisticated and intelligent, and stopping them will not be easy.

The industry has been working with the CRTC on a number of fronts in order to reduce both nuisance and fraudulent calls. ln that regard, I am pleased to be sitting on a panel today with representatives from both Rogers and Telus. It is unusual for me to take the time to acknowledge two of my competitors, but in this area of trying to reduce fraudulent and nuisance calls, it is important to note that we and many other players have been working together. In fact, our experts meet at least weekly, and often multiple times a week, to discuss these important issues.

When we deliver a call to you, we often display the number that is calling you. That is called a calling line ID, or CLID. In December of last year, the CRTC ordered carriers to start blocking calls that had a calling line ID or CLID that did not look like a real number. We refer to these calls as non-conforming calls. For example, if a call comes in on our network and has a CLID that exceeds 15 digits or is all zeros, we will block that call. To be clear, a non-conforming call is not necessarily a nuisance or fraudulent call, but having a non-conforming CLID is a very good indicator that a call may be problematic. On our network, we are now blocking approximately 220 million calls a month.

Another initiative the CRTC is pursuing is STIR/SHAKEN, which is the third topic the committee specifically asked about. STIR/SHAKEN works by letting consumers know that they can trust the telephone number that is being displayed. In other words, with STIR/SHAKEN, you will be able to know that the calling line ID you see on your phone is actually the real number calling you.

The CRTC recently sought comments on a proposal to require all carriers to implement STIR/SHAKEN. We support such a proposal. We think that we and all other carriers should be required to provide STIR/SHAKEN. However, we see STIR/SHAKEN as a long-term solution, as there is a variety of issues that need to be addressed before the benefits of a STIR/SHAKEN framework can be realized. It is for this reason that we, along with most of the industry, proposed that the CRTC STIR/SHAKEN mandate be delayed until we get the rules of the regime figured out. A lot of work needs to be done, and we are ready to do that work, but the industry and the CRTC must take time to do that work properly or else the solution will be flawed.

Let me give you an example. I think this is really an important point about STIR/SHAKEN. It's a long-term solution rather than a quick fix. Most phones today cannot display STIR/SHAKEN. Think of your land line telephone at home. Where would you see a check mark on your phone to confirm that the calling line ID displayed is actually the real number calling you? In fact, even most cellphones are not capable of displaying STIR/SHAKEN, although that will change in the next few years.

While we believe a mandate should be contingent on first finalizing the technical details, Bell has still committed to launch STIR/SHAKEN on portions of our network this September, but just because we launch it doesn't mean most Canadian consumers will be able to use it. There are a number of requirements that must be met in order for STIR/SHAKEN to fulfill its potential.

STIR/SHAKEN has promise, and we are fully committed to implementing it, but it is far from the only answer and will not materially address the problem of nuisance or fraudulent calls in the short term. Let me turn to something that I think will make a big difference.

ln addition to initiatives directed by the CRTC, we at Bell are committed to trying to protect our customers from fraudulent calls. Although we cannot identify all fraudulent calls, we have developed modern technology that allows us to identify millions of calls as being fraudulent.

ln identifying those calls, we work closely with the Canadian Anti-Fraud Centre, an affiliate of the RCMP. However, even when we can definitively identify a call as fraudulent, we are not allowed to block that call without CRTC permission.

Thus last year we applied to the CRTC for permission to conduct a three-month trial process we had developed for identifying and blocking fraudulent calls. I believe that's what the chair was referring to when he mentioned that there's an application; that's from us.

We have not publicly disclosed the details of this process so that we do not provide fraudsters with a how-to manual on the best way to circumvent our proposed trial; however, we have provided the CRTC with the full details of the process, and we've also shared the details of this process with our competitors, public interest groups and individuals who signed a CRTC-approved non-disclosure agreement.

If granted permission, we anticipate that this process will block approximately 120 million fraudulent calls a month on our network. That is in addition to the 220 million calls we're already blocking as a result of non-conforming calls. We suspect, however, that most of the 220 million non-conforming calls currently blocked are nuisance calls rather than fraudulent calls.

Our proposed trial will only block fraudulent calls in an attempt to protect Canadians from bad actors trying to illegally defraud them. We look forward to launching our trial as soon as we receive CRTC approval.

Fraudulent calls and nuisance calls are a pressing and growing concern for Canadians. We at Bell are fully committed to addressing this issue, including by asking the CRTC for permission to implement our new proposal to actively block these fraud calls. However, there is no one solution. We will continue to work with the CRTC, our competitors and our consumer groups to find new and innovative solutions to address this issue.

With that I will conclude.

Thank you.

[The Chair, Liberal, Sherry Romanado]

Thank you very much.

I'll just ask folks to every once in a while look up so they can see me waving at them.

The next group will be Rogers Communications.

[Howard Slawner, Vice-President, Regulatory Telecommunications, Rogers Communications Inc.]

Madam Chair, good afternoon. I'm Howard Slawner, vice-president, regulatory telecom at Rogers Communications. I am joined here today by my colleague Deborah Evans, Rogers' chief privacy officer. We appreciate this opportunity to appear before the committee and to provide input into the study of fraud calls in Canada.

Rogers fully supports the efforts of the Government of Canada and the CRTC to address the problem of nuisance and fraudulent calls. At best, these calls interrupt the peace and privacy of Canadians. At worst, they constitute crimes, often preying on the most vulnerable. Together these calls undermine the integrity of our national telecom system.

The unsolicited telecommunications rules, including the requirement to register with the national do-not-call list operator, have become well-established practices within the legitimate Canadian telemarketing community. In the 10 years that have passed since the introduction of the national DNCL, over 18,000 telemarketers and their clients have registered with the operator, respecting the privacy of the more than 13 million Canadian telephone numbers that have been enrolled.

There is, however, an important distinction between nuisance calls and fraudulent calls. Many nuisance calls are placed by legitimate parties, including not-for-profit and commercial organizations. While we can appreciate the frustration of Canadian consumers resulting from some of these types of calls, it's the growth in fraudulent calls that drives most concerns today.

The parties placing spam, fraudulent and blatantly spoof calls are aggressive and unrelenting, despite the established rules in place to protect consumers. Since they operate without fear of retribution or sanction, the mere existence of a national do-not-call list will not be sufficient to eliminate the issue. That is why Rogers, like its peers, is doing its utmost to eliminate these types of calls from our network. In fact, Rogers is diligently working to rid our network of all forms of unwanted mass calling. Over the last five years, Rogers has taken a leadership role in the industry, helping to spearhead several initiatives to tackle the problem.

Since 2015 we have worked with the CRTC enforcement branch to provide network resources, including telephone numbers and call routing, for the Canadian telephony honeypot project. This initiative collects data about fraudulent calls targeting Canadians in order to identify the methods used and assist with enforcement. For the last four years Rogers has also actively participated in the CRTC Interconnection Steering Committee, CISC, to review call blocking, STIR/SHAKEN and call traceback solutions. Rogers has taken a leadership role in many of these processes, including co-chairing several of these CISC working groups.

In 2017 and 2018, Rogers also took the lead in exploring and scoping an industry-wide filtering solution to reduce unwanted calls. Over 18 months, Rogers led a committee of 12 major carriers to assess various options. This culminated in an RFP to find a national analytics engine database, as well as a Rogers-specific RFP to potentially upgrade our network.

Finally, in 2019 Rogers worked with other Canadian telecom service providers to develop and deploy universal call blocking at the network level.

More recently, Rogers started to deploy STIR/SHAKEN. This technology will authenticate caller ID and is expected to be network ready by the end of 2020. Rogers has led many cross-industry committees to establish the best practices and mechanisms that will support its deployment, including the creation of the Canadian Secure Token Governance Authority to manage STIR/SHAKEN operations in Canada. In fact, we funded the initial work of the CSTGA.

Unfortunately, these solutions are time-consuming and complex to deploy. Telecom networks are designed to permit call completion, not prevent it, and blocking illegitimate traffic without interfering with legitimate calls is harder still. For example, while the telecom industry is working very hard on delivering STIR/SHAKEN this year, it still remains far from being launched on a commercial basis. Some standards remain to be defined, including how to display STIR/SHAKEN on the end-user devices. STIR/SHAKEN also requires end-to-end IP interconnection, which is a long time away.

Moreover, even as the industry adopts increasingly more countermeasures, the criminals are not resting. Their tactics and techniques continually evolve and change so that stopping unwanted mass calling becomes even more difficult. Most importantly, they are almost all situated offshore.

There is, however, much that can be done to combat unwanted mass calls. It will require the co-operation of industry, the CRTC and the Government of Canada.

First, the telecom industry must continue its current work instituting universal call blocking and STIR/SHAKEN. While these efforts will not end nuisance and fraudulent calls on their own and they will take time to fully implement, they do provide a foundation upon which other efforts can be based.

Second, the industry must continue to develop new methods of targeting these types of calls. Unwanted mass calling is an arms race, with each side continuously upgrading their efforts. New technologies and processes are being developed each year, and carriers must be quick to adapt and adopt.

Third, the CRTC should expand its enforcement of the rules. As the primary regulator of the telephone system, the commission must ensure that bad actors are punished. Since carriers are prohibited under the Telecommunications Act from simply blocking calls, the CRTC must be proactive in shutting down fraudulent calls when observed.

Fourth, the commission should target the points of entry in malicious calls. A large portion of international nuisance calls are coming into Canada through a small number of points of entry. The commission should therefore focus its efforts on why and how such calls appear to be entering Canada in this manner and what can be done to prevent it. It could emulate, for example, the efforts by the FCC, the U.S. Department of Justice and the Federal Trade Commission, which have recently worked together to stop incoming international robocalls at domestic telephony traffic gateways, that is, specific entry points into the United States.

Fifth, the CRTC can accelerate the deployment of SIP trunks. SIP interconnections allow carriers to adapt better technologies that can combat malicious calls, STIR/SHAKEN in particular. SIP, however, is not mandated at this time, and some carriers are deploying it sooner than others. The commission should be pressing for its widespread adoption.

Sixth, the Government of Canada itself has a crucial role. The overwhelming majority of nuisance and fraudulent calls originate abroad. The government, through Global Affairs Canada and the RCMP, must work with its foreign counterparts to shut down the call centres and robocall platforms that originate these fraudulent and spam calls. As long as these parties continue to operate with impunity, they will simply find new and alternative ways to circumvent the protections and measures implemented by telecom service providers to defeat this problem. There is no better way to stop these calls than at their source.

Last, there is an important educational component. Every stakeholder can help Canadians become more aware of how to avoid the scams that are driving these fraudulent calls. Rogers has resource materials available on our website to help consumers spot a telemarketing scam, how to protect themselves from caller ID spoofing and spam calls and how universal call blocking helps protect them.

At the same time, organizations such as the Canadian Anti-Fraud Centre are active in educating consumers about frauds, including those that abuse the telephone system, and in improving awareness of the techniques employed by the fraudsters, but they, along with all of us, should do more on this aspect, especially with vulnerable people and immigrants.

Rogers looks forward to working with its peers, the CRTC and the government to address this critical issue for Canadians. Thank you for the opportunity to participate in this review. We are happy to answer any questions you may have.

[The Chair, Liberal, Sherry Romanado]

Thank you very much.

Our next eight-minute round will go to Monsieur Birot with Telus.

[Jérôme Birot, Vice-President, Voice and Services Development Operations, TELUS Communications Inc.]

Thank you.

Madam Chair and honourable members of the committee, my name is Jérôme Birot, and I am the vice-president of development operations for telephone and value-added services at TELUS.

I'd like to begin by thanking you for the opportunity to address the committee today on the important topic of fraudulent telephone calls. With me for this discussion is John MacKenzie, TELUS's director of regulatory affairs.

As part of our first promise to customers, Telus has been devoting significant resources over the last few years toward finding a solution to the issue of fraudulent calls. However, it's not an easy issue to solve.

Companies around the world are struggling to find a solution. Global telecommunication networks have evolved to seamlessly connect people and data wherever they may be in the world. With the emergence of a truly global economy, these networks are being exploited by thieves and criminals at home and abroad intent on defrauding Canadians through fake and fraudulent phone calls.

I am often asked, “Why can't you just stop calls from the scam artists?” Unfortunately, fraudsters use sophisticated methods to mask the origin of their calls. They are extremely effective at blending their fraud calls with normal, legitimate network traffic as it is routed around the world. By the time they reach our shores, it is very difficult to distinguish between a fraudulent call and a legitimate call.

Since we have a regulatory obligation to allow legitimate calls to either terminate on our network or transit through it, the calls are routed to their intended destinations. When we are able to identify fraudsters, we do our best to block their calls. These are often static methods, and are not effective in a dynamic environment. So what can we do?

There are third party apps and capabilities provided by smart phone manufacturers, allowing users to block or filter their calls. They can prove cumbersome for consumers to use or may not be very effective. In addition, there are several types of systems that telecoms use to limit fraud calling in the network, such as call blocking and call filtering.

Call blocking systems, such as universal call blocking, or UCB, involves the telecommunications service provider blocking suspicious calls originating or terminating on its network, or passing through its network. For example, a calling number with all zeros would be blocked. On the other hand, call filtering systems are controlled by customers. They filter calls based on their preferences, and do not affect calls to anyone else.

At Telus, we offer a call control service, a proprietary call filtering system provided free of charge to most of our home phone customers. Call control is designed to be simple for our customers to activate and simple for them to use.

To explain how it works, I will use the hypothetical example of me trying to call you, Madam Chair. You will be a Telus customer. You will have activated call control on your phone. When I call your phone number, my call will be intercepted by the network before it reaches you. I will then hear the following message: “This number is call controlled. To get through, please press...”. Then it will prompt the caller, me, for a random number between zero and nine. We call this the challenge. I then have to press the correct number. When I do that, my call to you will be connected and your phone will ring. If I press the wrong number or do not press any number at all, my call will be rejected. I'll hear a voice recording indicating that you are not receiving calls. More importantly, your phone will not ring.

It's proven very effective at filtering out fraudulent calls, because those calls are typically autodialed by a computer system, and computer systems lack the ability to follow the instructions from the challenge.

Call control can also be customized through the use of personal lists, such as accepted callers and blocked callers. If a phone number is on the customer's accepted callers list, it will bypass the challenge. If, on the other hand, a phone number is on the customer's blocked callers list, it will be rejected.

We also have another list unique to each customer called the recent callers list. The recent callers list, which is controlled by Telus, comprises the last 10 phone numbers that have successfully passed the challenge. Phone calls from these numbers do not get challenged until they are overwritten by more recent calls.

In my previous example, this will mean, Madam Chair, that your friends and family who call you often would not have to pass the challenge every time they call you.

The results of call control have been impressive. Since its initial introduction in May 2018, we have determined that call control is significantly more effective than UCB, blocking 40% of incoming calls to customers who have activated the feature. Call control is also almost immune to spoofing, namely, where fraudsters hide their identity by faking a genuine number, like the one here today or one from a local area code. Due to the success of call control, we have been working on enabling it for our wireless customers. We expect to make it available to them in the coming weeks.

Switching gears, I would like to conclude by talking about STIR/SHAKEN. STIR/SHAKEN is neither a blocking system nor a filtering system. It is a set of protocols designed to validate the integrity of the caller ID and to provide the customer receiving a call with the assurance that the calling number belongs to the caller. Voice service providers who fail to support STIR/SHAKEN will likely find themselves at a competitive disadvantage. It is clear that STIR/SHAKEN has momentum in North America, and I expect it will be adopted shortly thereafter in Canada.

Telus is among the Canadian service providers that established a new corporation, the Canadian Secure Token Governance Authority, to support the implementation and operation of STIR/SHAKEN in Canada. However, there are still many issues that prevent STIR/SHAKEN from fully addressing the problem of fraudulent calls. The most significant of these issues is that STIR/SHAKEN standards will apply to calls within Canada initially, and at best within North America. However, many fraudulent calls originate from outside Canada. Another issue is that the system does not work if there is legacy circuit-switched equipment anywhere in the call path, which is common across networks that have been in operation for decades. Finally, we do not know how smart phone manufacturers will embrace STIR/SHAKEN standards or display STIR/SHAKEN information on their devices.

As a result of these challenges, and until STIR/SHAKEN standards are adopted globally, we do not know when STIR/SHAKEN will meet the high expectations that many have for the technology. Notwithstanding these issues, Telus is supportive of STIR/SHAKEN. We're confident that its capability will continue to improve. While we likely cannot offer STIR/SHAKEN sooner than in the U.S., we expect that Canada will follow shortly thereafter. In the meantime, we're confident that call control will provide effective protection for Telus customers.

That concludes my opening remarks. I welcome any questions you may have.

[The Chair, Liberal, Sherry Romanado]

Thank you very much.

Before we begin our six-minute round, I want to remind people in the audience that there is absolutely no photo taking allowed during committee.

With that, we'll start the first six minutes with MP Gray.

[Tracy Gray, Conservative, Kelowna—Lake Country, BC]

Thank you, Madam Chair.

Mr. Birot, you mentioned STIR/SHAKEN. I have noticed through my research on the issue that it's in emulation of a model that was implemented in the U.S. for fraudulent calls. Has your corporation studied any other models, or fraud calls being used locally? If so, are there other models that you feel might emulate this a bit better, or any components that you think might be useful to add?

[Jérôme Birot]

Yes. We have the call control service, which we believe can tackle the vast majority of those fraudulent calls. STIR/SHAKEN is a great way to augment this, but call control, for now, helps us and helps our Telus customers.

[Tracy Gray, Conservative, Kelowna—Lake Country, BC]

Great. Thank you.

Mr. Daniels, you mentioned that Bell has proposed that the CRTC STIR/SHAKEN mandate be delayed until we can get the rules of the regime figured out. The process for the model was started back in 2015 by the CRTC. That was five years ago. How much more time do you think you need?