Mobile carriers continue to require TCR registration for telephone numbers that are routed through a virtual phone service provider ("service provider"). Most, if not all, service providers have created separate divisions to oversee the review of client telecommunications campaigns. Only after approval by its service provider, will a company's 10-digit long codes ("10 DLC") be registered with major mobile carriers. After successful TCR registration, company text messages are unlikely to be blocked or delayed.
As our readership is aware, TCR registration is a comprehensive and arduous process. To help secure successful registration, among other measures, companies should ensure that their text messages do not contain restricted content.
TCR Campaigns Cannot Contain Prohibited Content
On January 26, 2023, a 10DLC Campaign vetting process was instituted by mobile carriers. In an effort to reduce consumer exposure to unwanted text messages, carriers began denying TCR registrations submitted by businesses that promote certain prohibited content. Prohibited content includes, but is not limited to:
- High-risk financial services – i.e. payday loans, short term high-interest loans, cryptocurrency, etc.;
- Third-party lead generation services and affiliate marketing;
- Debt collection or forgiveness – i.e. third-party debt collection, debt consolidation, debt relief, and credit score repair;
- Gambling;
- Illegal substances – i.e. cannabis, drug paraphernalia, fireworks, etc.; and
- "Get rich quick" schemes.
Additionally, mobile carriers have made clear that campaigns that promote hate speech or involve the transmission of sexual content will be summarily rejected.
Retain Legal Counsel to Assist With TCR Registration
The TCR registration process involves many steps and regular correspondence with service provider representatives. Reviewing proposed text message content is only one of the many measures that a business should take in advance of submitting a TCR application. Retaining experienced TCR counsel to work with your company to ensure that best practices are implemented will expedite the TCR campaign registration process.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
