Business Text Messaging Requirements

Business person sending a text message on a mobile device

Business Text Messaging Requirements

Last Edit: 4/20/23

Executive Summary

The FCC, as part of the Telephone Consumer Protection Act, has ruled that consumers are entitled to protection from unwanted text messages. In 2019, the Cellular Telecommunications Industry Association (CTIA – a trade association representing cellular carriers in the US – AT&T, Verizon, T-Mobile, etc.) released Messaging Principles and Best Practices to satisfy these requirements.

A core component of this protection is based on registration of business text messaging traffic that originates from 10-digit local phone numbers (aka 10DLC, or 10-digit long code).

POPP’s partner organization for text messaging, in conjunction with the major cellular carriers, is requiring all business text messaging traffic be properly registered as of 3/31/23. At this time, unregistered text messaging traffic will still go through. However, if clients are experiencing their text messages getting blocked or marked as “potential spam”, no technical support will be provided to resolve any such issues until the text messaging traffic has been properly registered. 

In order to register your text messaging traffic, you will need to complete and return a form emailed to you from POPP. POPP will submit your answers to the registrar, a 3rd party company called The Campaign Registry (TCR). TCR and the cellular carriers evaluate each registration based on an undisclosed algorithm that takes into account a brand’s past texting history, type of organization, and the type and quantity of messages your company plans to send.

Please review the information below, as it will answer many common questions:

You will need to register for 10DLC if your business has POPP’s Hosted IP Phone System (aka Cloud VoIP Phone System) and you have (or will have) phone system users enabled for text messaging using the MaX UC desktop/mobile app.

As stated above, the cellular carriers are requiring business text messaging traffic to be registered to satisfy FCC requirements.

Industry-wide, the 10DLC registration is heavily aimed at enterprise texting platforms that can send out large volumes of automated text messages. An example might be a restaurant's reservation platform that sends out automated reservation reminders and weekly deals.

While texting from MaX UC is strictly person-to-person and likely occurs in relatively low volume, because it originates from a business and from a 10-digit number, it is required to be registered all the same.

The process to register is as follows:

  1. Client completes the Text Messaging Registration form sent from POPP.

Within the form email, you will set up a Brand and a Campaign:

  • Brand: The Brand is the business entity that any given texting-enabled phone number is associated with. You will need to supply some basic information about your business.
  • Campaign: The Campaign details the type of text messages the phone number intends to send. You will need to supply information and samples including who you are sending text messages to and why.
  • Best Practices: You will also need to affirm that you are following best practices (see below).

Important: The form includes example answers to help guide you in your responses. Answer each question honestly and completely. Incomplete or vague responses may add delays to the process. Businesses found to be providing incorrect information on their registration form may have their campaigns suspended.

  1. POPP will submit the registration on your behalf to the carriers. You may be contacted by POPP or the cellular carriers with additional questions. The carriers will evaluate your submission.
  2. Once approved, POPP will associate your texting-enabled phone numbers to your Brand and Campaign and then POPP will contact you once completed.
We're here to help. If you have questions or need assistance, please contact us at 763-797-7900 or helpline@popp.com.

In general, businesses must ensure they are not sending text messages to anyone who has not already given  them permission to do so, called opting-in. Additionally, businesses must respect the wishes of anyone who informs you that they no longer want to receive your business text messages, called opting-out.

  • Opt-in: You will be required to affirm that you have a system for collecting opt-ins.
    • If your business has an official form on your website where your customers provide their phone number and check a box indicating their willingness to receive your text messages (or something similar), that’s a good example of an opt-in. On the form, describe that process. The opt-in must be clear and conspicuous, and not obscured deep within your Terms of Service. If you are currently sending proactive text messages without first getting an opt-in, you must create an opt-in process.
    • If you are like many businesses who simply use texting to casually converse with your customers, then you should ensure that your employees are trained to only respond to customer-originated text messages, and only with responsive information. In other words, if your employees receive a text from a customer, they may respond to the text and converse with the customer until the conclusion of that interaction. However, they should not be texting that same customer later on with “special offers” or other information the customer did not request and is not expecting.
  • Opt-out: You will be required to affirm that you honor opt-out requests.
    • If your business receives a text message from customers with STOP or you otherwise receive a request from a client to discontinue receiving your text messages (verbally, over the phone, etc), your employees should be trained to honor the request and ensure that the customer is removed from your opt-in list and no longer receives any future text messages.

The registration form includes some example verbiage for how to describe your opt-out process.

  • Help: You will be required to affirm that you manage Help requests.
    • If your business receives a request in the form of HELP, or a similar indication of confusion on the part of the customer, your employees should be trained to respond with a message of how the person can contact you by another means other than texting, e.g., your website, an email address, or phone number.

The registration form includes some example verbiage for how to describe requests for HELP.

Be sure that the information you provide during registration is complete and accurate, and includes a detailed description of your use case and sample messages. Carriers use automated content-based filtering to check campaigns, so if the messages you send violate the guidelines listed below or don’t adhere to the use case you provided during registration, your campaign may be suspended.

Your content may be subject to review, so knowing what types of content to avoid will keep your messages from being flagged. Here are the content types to avoid:

  • Promotional messages with toll-free numbers
  • Fraud or scam messages that involve wrongful or criminal deception intended to result in financial or personal gain
  • Deceptive marketing messages that do not meet the standard held by the Federal Trade Commission’s (FTC) Truth in Advertising rules
  • S.H.A.F.T. (sex, hate, alcohol, firearms, and tobacco) content
  • Sensitive content such as:
    • Betting-related content — game bet, lucky draw, etc.
    • Debt restructuring/refinancing offers
    • Debt relief offers
    • Payday loan offers
    • Home loan offers
    • Education loan offers
    • Insurance quotes (unsolicited)
    • Earn money from home job offers

In extreme cases, carriers might decide to block a brand or a campaign. 

Please be sure to complete the registration form accurately and in a timely manner as carrier vetting can take several days and incomplete forms will only delay the process. The information provided herein is designed to help reduce the chances of POPP clients’ having their Brand and Campaign registrations denied and/or their text messages getting blocked. This content should not be considered legal advice or a substitute for qualified legal counsel. Please understand that these requirements are being instituted by the cellular carriers and not POPP.

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Outbound Voice Calls Flagged as Spam

Outbound Voice Calls Flagged as Spam

Last Edit: 1/11/23

This content is designed to provide POPP clients with information about how and why Caller ID for outbound calls made from their business phone number(s) may get marked with “Spam” or similar. It will provide resources to minimize your chances of it happening in the first place, as well as steps to take to remedy the situation if it has happened to your calls.

A smartphone with an incoming call flagged as Spam.

Background

Spam calls are any type of call that is unsolicited and unwanted by the person receiving the call. Spam can come from legitimate businesses trying to sell you a real product/service, or from a scammer trying to swindle you in some way.

The sharp rise in annoying and illegal robocalls and other phone scams in recent years has created the need for systems to protect consumers from these calls. According to Hiya.com 2022 data, an estimated 80.1 billion Spam and fraud calls were placed in the US in 2021 alone. As a result, 94% of consumers are highly skeptical of incoming calls they are not expecting. If the people you are calling are seeing “SPAM” or “SCAM LIKELY” or similar text on their caller ID, it is because their phone carrier (aka “the far-end", not POPP) has built or integrated with an automated system that looks for calling patterns in their network that are similar to known spammer activity. These systems also take into account the “reputation” of the phone number which can be influenced by a variety of factors like having a complete “Google My Business” listing (more on this to come) and by measuring how often the people you’re calling flag your calls as Spam. These spam blocking systems are most heavily implemented at major carriers like AT&T, Verizon, and T-Mobile, but this technology is not exclusive to cellular carriers and has been implemented by many landline providers as well.

Most carriers (including POPP) have started to implement a technology called STIR/SHAKEN which was mandated by the FCC and is designed to help carriers more easily identify the source of illegal robocalls and go after the people that are initiating them. However, it is important to distinguish that STIR/SHAKEN is primarily designed to combat illegal calling, whereas Spam blocking tools are designed to help people block unwanted calls – whether they were placed legally or not. 

The short answer is that there is no short answer.

The effectiveness of any system that shields people from unwanted calls (or otherwise defends against ANY unwanted activity) depends on a certain level of secrecy about exactly how it works. If carriers published exactly what must happen in order for calls to be marked as Spam, it would provide a roadmap for spammers on how to operate in a way that avoids detection. Each carrier maintains their own system with their own custom criteria and settings about what exactly qualifies as Spam calling in their eyes. These systems use Artificial Intelligence and Machine Learning to analyze patterns in millions of calls per day to assign a reputation score to phone numbers and make decisions about which calls to flag as potential Spam.   

In general, the following criteria will lower the reputation score of a calling phone number: 

  1. High quantity of outbound calls per day/hour. Spammers are known for making MANY calls each day. 

  1. High quantity of short duration calls. Many calls from spammers result in very short calls, as people quickly hang up if not interested. 

  1. High percentage of calls that are unanswered, or that don’t result in a voicemail being left. 

  1. Calling the same numbers repeatedly over a short period of time.  

  1. Your phone numbers have not been properly associated as a known (legitimate) business entity. See Free Caller ID Registries and Google my Business sections below. 

  1. People that you are calling are marking calls from your number as Spam via their cell phone or in their carrier's app/portal. Smartphones in particular make it incredibly easy for consumers to block/screen calls they are not interested in receiving.

What are my options and resources to resolve this?

The first thing you need to do is honestly evaluate the types of calls you’re placing. Ask yourself “am I placing a large quantity of calls that the recipients are not expecting and/or do not want to receive?” If the answer to that question is “yes,” then unfortunately the marking of Spam on your calls is probably valid. You may have an amazing product or service, but it ultimately comes down to whether the people you are calling are receptive to receiving your unsolicited calls. If a high percentage of people hang up on you, or ask not to be called again, then a high percentage of them are also probably marking your calls as Spam.   

You can follow the steps below which may help. But as long as you continue to place large quantities of unsolicited and unwanted calls, any resolution that removes the Spam label on your calls will probably be short lived as people will continue to block your calls or mark your calls as Spam. 

If you are confident that your calling does not qualify as Spam, then follow the steps below to work to remove the Spam designation from your calls. 

 https://www.freecallerregistry.com/fcr/ and https://www.calltransparency.com/  These registries are the closest thing to a centralized system of verified/legitimate business phone numbers and information is shared to some extent between multiple Spam detection companies (First Orion, HIYA, TNSI, and many major carriers).   

However, registration will not make your outbound caller ID permanently immune to being marked as Spam if a significant number of people that you are calling continue to mark your calls as Spam. 

Note: Registrations must be done by the business entity, not POPP. 

You may be able to register your business numbers with these carriers as “legitimate” and/or notify them that they have incorrectly flagged your calls as Spam. If your customer informs you that your call showed up as Spam on their phone, ask them who their phone carrier is. 

If the far-end carrier that is marking your calls as Spam is not listed above, you will need contact that carrier directly to determine their process for getting the Spam designation removed.   

Note:  Requests to register your phone numbers and report calls that were mis-categorized as Spam must come from the business entity, not POPP. Furthermore, POPP does not have any additional “back-channel” means to contact these carriers beyond what is listed above. Nor can we escalate issues if you do not get a satisfactory response.

This listing provides Google with all the important details about your business, helps verify the legitimacy of your business, and impacts what gets displayed for caller ID, specifically when calling Android cell phones and potentially other carriers who integrate with Google. You can setup a listing here: https://www.google.com/business/ 

Note: Registrations must be done by the business entity, not POPP. 

Use a legitimate/valid outbound caller ID phone number and business name so that people can easily identify you.

Ensure that the number you present for outbound caller ID is answered if someone tries to call you back. 

Do not call people repeatedly, especially if they indicate that they are not interested in your services. 

If you call someone and reach their voicemail or they use a call screening service (like Google Assistant), leave them a clear message about who you are and why you were calling. If you simply hang up, it increases the chances they will flag the call as Spam.

Follow the FTCs rules for telemarketing https://consumer.ftc.gov/articles/national-do-not-call-registry-faqs

If after taking all of the steps above, your calls continue to get marked as Spam, you may need to consider other means (e-mail, texting, social media, direct mail marketing) to connect with your prospects and customers – especially if a significant amount of your calling is telemarketing or another form of unsolicited and unwanted calling.

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