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Voice & SMS Compliance for Political Candidates & Non-Profits (501c3’s and 501c6’s)

Are you familiar with Gary Vaynerchuck? Gary is the owner of Vayner Media and widely considered one of the top digital marketers in the world. He also has a prevalent saying;

Marketers Ruin Everything. ~Gary Vaynerchuck

Indeed that is the case with programmatical voice, SMS, and MMS marketing. Programmatical voice and text has EXPLODED in the past 5 years with the likes of businesses, government entities, non-profits, and political candidates leveraging the power and scalability of these solutions.

The net result of explosion is that it has empowered bad actors to exploit and abuse the privilege of programmatical voice and text. What do we mean by bad actors? Bad actors that willfully and knowingly violate the rules of SMS laws and regulations. It has become REALLY BAD (trust me).

So what's next? With pressure from the top down, specifically from the FTC and other federal government agencies, mobile carriers are now taking action to enact new rules of engagement to prevent bad actors from operating. These actions include enhancements to A2P 10DLC.

A2P 10DLC refers to a system in the United States that allows businesses to send Application-to-Person (A2P) type messaging via standard 10-digit long code (10DLC) phone numbers. In short, recent changes and enhancements to A2P 10DLC policies and rules are akin to, "US mobile carriers policing themselves and their programmatical voice and SMS partners before the federal government steps in and implements prohibitive regulations." Consumers are not happy (actually quite pissed) and have voiced their concerns with politicians. The mobile carriers are quite aware of this problem and are being pro-active.

The mobile carriers leading the charge with new A2P 10DLC changes include the usual suspects; T-Mobile, Verizon, AT&T and others. Verizon is ahead of the curve, they implemented their own A2P 10DLC policies in 2019, the other carriers are playing catchup. The carriers have laid out new ground rules and requirements for their programmatical voice and data partners, the data partners include Twilio, Amazon, and Google just to name a few. In essence, the carriers have said to these partners; "Here is a new list of rules and requirements. If you and your customers want to do business with us mobile carriers, you will need follow these new rules and requirements. Period, end of story, full stop."

So the Twilios, Amazons, and Googles of the world began communicating these changes to their customers in the spring of 2021. The communications have included the new rules, changes, milestones, and deadlines for the policies.

How does A2P 10DLC work?

There are two important requirements under the new A2P 10DLC system:

  • Businesses must identify who they are to the carrier networks (Brand registration).
  • Businesses must register what type of messages they are sending, i.e. notifications (Campaign registration). 

It's that simple! Carriers are now insisting that every single message (voice or text) received by a mobile consumer can be traced back to the originating brand AND that "type" of message must be registered with the carriers. The "type" of message is a little confusing at first, but a simple example would be;

Company A sells T-Shirts, they are registered as an S-Corp with the mobile carriers. They register a type of message that includes marketing promotions and sales receipts. This allows Company A to send text messages to their opted-in customer about new T-Shirts and send purchase receipts by text, SMS, or MMS. Company A suddenly starts sending text messages that ask for donations to a non-profit. The donation "type" of request was never registered and Company A is now at risk of having that type of message not be delivered AND they will lose "trust" with the carriers which ultimately can and will impact deliverability of all messaging.

A2P Exemptions

There are exemptions for A2P messaging type registration, however there are not exemptions for A2P brand registration. Some of the exemptions include;

  • Toll Free 855 and 866 Numbers
  • Non-profits: 501c3's and 501c6's
  • Government Entities (i.e. Secretary of State, etc.)
  • Political Candidates

Twilio Specific Compliance - ISV's, or Independent Software Vendors (aka Agencies)

For ISV's, create a primary customer profile. The deadline for creating these profiles was July 9th however you have until July 15th until to submit your Primary Business Profile and A2P Brand Registration. Your primary customer profile will serve as an umbrella for July 2021.

Twilio Specific Compliance - Direct Brand or Businesses with Multiple Sub-Accounts

If you are a “direct brand” (a company sending messages as yourself, and not on behalf of other businesses, example Ford Motor Company registered as one company with many dealership sub-account) with messaging use cases spread out across subaccounts, please be sure your Primary Business Profile and Brand Registration is complete by July 9, 2021. Twilio will automatically apply this registration across your subaccounts between July 15 and July 30. You will be notified when this occurs, allowing you to register any messaging traffic on your subaccounts.

A2P Exemptions

There are exemptions to A2P. The exemptions do, however, require brand registration and message type registration. If you meet the conditions for a Special Use Case (including toll free 855/866, 501c3, political, government, and emergency services), further instructions are not available as of this moment (July 12th, 2021). We will provide more registration guidelines as they become available.

A2P 10DLC Registration and Carrier Fees

A direct communication from Twilio regarding new carrier fees;

A2P 10DLC Summary & Takeaway

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