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A2P Compliance - 10DLC and Toll-Free

Preparing for Brand and Campaign Registration

In preparation for AT&T’s launch of their A2P (Application-to-Person) 10DLC service, we want to provide you with five steps you can take now to prepare for the rollout. We are anticipating an official launch of AT&T 10DLC in first-quarter 2021 and will require registration completion well in advance of that. We will continue to provide details of their full commercial launch as we receive additional updates. This change will affect the way you use 10-digit long codes to facilitate SMS communications. Note that toll-free numbers are not governed under this launch, only U.S. standard 10-digit long codes.

iconectiv®’s TruReach Deliver Aerialink is here to facilitate this transition for you. In the coming weeks, we will be registering your brands and campaigns for 10DLC. We are currently working on the forms and backend processes to gather your registration information and will let you know as soon as these are available.

Here are the steps you should take now to lay the groundwork for successful implementation.

Step 1: Gather your company information for “Brand Registration.”

A brand is a business or individual behind the campaign and the entity responsible for the messaging content in a campaign. As your Campaign Service Provider, TruReach Deliver Aerialink submits your brand and campaign details to the 10DLC Registry. The Registry will perform verifications of every brand registered.

Here is a short list of typical brand information required.

  • Company’s legal name
  • Brand URLs
  • Contact information
  • Tax ID/ Employee ID Number (EIN)

For detailed information, see the Brand Registration section of the A2P 10DLC Brand and Campaign Registration Information document.

Step 2: Assess your SMS campaigns/programs and their use cases for campaign registration.

How are you using long codes for messaging currently? Categorize your message content based on the use cases outlined in the campaign registration section of the A2P 10DLC Brand and Campaign Registration Information document. Here is a preview of some of the information required to register each campaign:

  • Use case
  • Campaign description
  • Sample message
  • Weblinks in your message content
  • Opt-in and opt-out information
  • 10-digit number for message delivery

Some special campaign use-cases require the brand to be vetted by a participating vetting provider.

Step 3: Decide which 10-digit long code(s) will be associated with each of your campaigns. Note: a single number cannot be associated with more than one campaign.

There is a new carrier expectation that standard campaigns will utilize only one long code for sending and receiving messages. However, there can be exceptions. For instance, a company with multiple locations, each with a different text-enabled number sharing the same customer care use case could potentially qualify for an exception. We can request that the carrier reviews the special use case.

AT&T will assign your campaign’s allotted throughput based on the use case. AT&T is finalizing their throughput limits. Once these have been confirmed, we will share the details.

Step 4: Submit your brand and campaign information.

As mentioned, we will provide a form where you can enter the necessary brand and campaign information. Once submitted, we will register your brand and campaign(s) on your behalf. When successfully registered, each campaign will be assigned a campaign ID, which is used to tag all long codes in that campaign.

###Step 5: Review A2P 10DLC fee model.
We are waiting on the AT&T internal teams to provide final surcharge and 10DLC fee information. When AT&T announces these details, we will let you know as soon as possible. We anticipate that the rollout of AT&T’s 10DLC implementation will introduce the following fees:

  • Brand Registration fee, a one-time setup fee, may vary by carrier.
  • Campaign Registration fee, a per campaign submission, Monthly Recurring Charge paid quarterly.
  • Number Registry A2P10DLC fee, a per number Monthly Recurring Charge in addition to the current base Number Registry fee.
  • Outbound message surcharge fee, AT&T is expected to have a range of surcharge fees that vary by campaign type. The message class assigned to your campaign will determine the outbound message surcharge fee.

Per our previous notifications, carriers are introducing A2P 10DLC service to provide a sanctioned platform for commercial messaging using long codes. Their objective is to protect consumers from unwanted spam, while still allowing businesses to better connect with their customers.

We look forward to partnering with you to work through this transition and create an environment in which A2P 10DLC can thrive as a reliable commercial messaging service.

U.S. A2P Customer Obligations

Aerialink is committed to creating a healthy messaging ecosystem that serves all participants and to keeping our customers informed about recent changes in the industry, including the CTIA Messaging Principles and Best Practices.

All customers sending A2P traffic are subject to the guidelines for A2P traffic set by the CTIA.

The number types that deliver messages over an A2P service include:
short codes
toll-free numbers (800, 833, 844, 855,866, 877, 888)
standard 10 digit numbers on the following schedule:

  • Verizon MMS A2P service rolled out Jan 14, 2020
  • Verizon SMS A2P service effective Feb 1, 2020
  • Other carriers A2P service – TBA

Note that any and all participating carriers may include their own, additional rules and regulations for what constitutes A2P messaging above and beyond the definitions found in the CTIA Best Practices Guidelines. We recommend that you check these pages regularly for updates as the telecommunications ecosystem continues to evolve. As such, the information below may be updated or changed without notice.

The following guidelines should be maintained by all Aerialink customers for compliant A2P messaging. In addition to our Acceptable Use Policy, Aerialink customers using A2P messaging routes:

  1. Must obtain express consent prior to sending messages to any recipients.
  2. Must provide an opt-out method, permitting end-users to decline to receive any further messages.
  3. Must not send messages violating CTIA or carrier rules or regulations for acceptable A2P messaging. Note that these rules and regulations are subject to change. Those changes will be reflected in the Aerialink Acceptable Use Policy.
  4. Understand that carriers reserve the right to re-evaluate messaging use-cases at any time and may shut down existing messaging programs at their discretion.
  5. Must, if intending to resell A2P services, assume responsibility for the maintenance of compliant rules and regulations equal to or greater than those imposed by the CTIA, carriers and Aerialink.
  6. Must, if intending to resell A2P services, obtain use-case information from all clients and maintain the right to audit said programs. Aerialink customers must be able to provide this information to Aerialink upon request.
  7. Must not use A2P messaging services to send Protected Health Information.
  8. Must provide appropriate security and privacy controls to protect subscribers and maintain opt-in and opt-out integrity and full confidentiality of end-user information.
  9. Must provide terms of service and privacy policy.

Disallowed Provider Behavior

The following traits are considered by the carriers to be suspicious and indicative of spam or fraudulent traffic. As such, campaigns found to be doing the following are not complying with best practices guidelines:

  1. Snowshoeing - utilizing a large block of numbers to spread high-velocity traffic among them to avoid carrier spam filters.
  2. Ignoring or Avoiding Opt-Outs - any attempts to make it difficult for an end-user to opt out run the risk of noncompliance with the FCC TCPA, as are instances of ignoring opt-out attempts made in a reasonable manner.
  3. URL Cycling, Redirects and Forwarding - campaigns utilizing strange or misleading URL behavior to manipulate end-user consent, attention or capture information.
  4. Number Cycling - dropping blocks of numbers which have been burned by the carriers and replacing with fresh numbers to simply repeat the process.

Deliverability Best-Practices

The following recommendations help ensure compliance with CTIA and carrier guidelines, as well as maintain best deliverability with lowest risk of incurring carrier blocks.

  1. Use as few numbers for your campaign as possible. While there are some use-cases which require the use of multiple numbers (e.g. your company has different departments and you want a different TFN for each), limit the use of one number per clear use-case (e.g. one number per department rather than two). This helps to allay carrier concerns of snowshoeing.
  2. Keep branding, URL domains and messaging consistent. Multiple names, differing or changing URLs and mis-matched content cause confusion and concern.
  3. Keep phrasing conversational. Messages that sound like the transcribed words of a carnival barker will always appear spammy, even if they are legitimate.
  4. Obtain consent directly. Consent should be obtained directly from the end-user to receive the text messages you intend to send.
  5. Maintain expected frequency. If your advertising told end-users they would receive messages once a month, hold to that. If your advertising doesn’t indicate frequency at all, it might be time to add it.

Aerialink Compliance articles are for informational use only. They do not constitute, and should not be taken as or in place of, legal advice. Aerialink customers are responsible for meeting all legal requirements applicable to their programs and are strongly encouraged to consult formal legal counsel.