We're in the same situation, but we communicate only with our employees via Ring, no coordinated SMS campaign reaching out to Customers.

I understand it's frustrating, but this is the practice industry-wide and we are working to be in compliance with the expectations for the carriers.
Did you fill out the TCR form yet?
If not, I would encourage you to go through the motions to ensure you do not lose this feature as we approach the March 31st deadline.

Thank you Becky. But what is the purpose to register if we have to identify a Brand and Campaign? And that we will adhere to the requirements to obtain consent, track consents, provide opt-in and opt-out language, provide help keywords and sample SMS messages? All just to directly communicate to a client. We are better off turning off SMS through Ring Central and avoid breaking the terms and content policies of Ring Central.

I have the same issue. We filled out the TCR form already. Already registered but all the options in the campaign section are not applicable at all. (we also use sms internally) How would I go about filling it out? (The consent section does not apply at all)

I don't think carriers thought this through. There should have been an option to attest to the fact that a user doesn't use SMS for marketing purposes, automated communications for appointments or reminders. And an option to indicate it on the application. If a user gets "caught" using it incorrectly then that can be addressed by the provider and carrier.

Ring Central WILL lose clients over this. There are simply too many businesses that do not use SMS other than to reply to an SMS initiated by the customer.

Since the regulation is vague (it is my opinion) that Ring Central's Legal Department DGAF, and will not risk massive Federal Penalties for Ring Central (which, to be fair, is Legal's job).

We see similar instances across industries where a company's Legal Department interprets the rules as conservatively as possible. For example, one online music retailer has lost 1/3rd of their customers after changing policies to treat individual sellers of used gear as if they were full-fledged LLCs, Corps, or LTDs. The law does not require that, but legal decreed it was too difficult to separate individuals vs companies (despite having EINs vs SSNs as a bright-line separator).

I applaud the government trying to quash SMS SPAM, but they throw out the baby with the bath water.

We may use text messaging via RC to respond on a one-off basis. How am I supposed to create a campaign for that? I also need to understand the consent part of the process. If we are only sending responses to internal communication or responses to an incoming message, how do we obtain consent? We do not use the SMS text message feature for mass messaging. I don't have a problem setting this up and paying the fees but we need to know how to set this up properly. Is it possible to have RC create a template for a campaign for this purpose and as an administrator we can just use that template?

Tim, "campaign" is the way that TCR describes it, but it's actually your use case - which sounds like it is conversational.

This information might help, but feel free to share additional questions here:

Implied Consent (Conversational Messaging Content)

• First message is only sent by a Consumer
• Consumer initiates the conversation and the business simply responds.
• Does NOT provide consent for informational, promotional, or future messaging unless recipient provides consent during conversation

Express Consent (Informational Messaging Content)

• Consumer needs to agree to receive texts for a specific purpose when they give the business their mobile numbers
• Consent must be specific for SMS, general language including “opt into communications” is not considered sufficient (instead say “opt into receiving SMS)
• Does NOT provide consent to be notified of promotional messages unless recipient provides consent to be added to the marketing list.

Express Written, and Logged Consent (Promotional Messaging Content)

• Consumer needs to agree to receive texts for a specific purpose when they give the business their mobile numbers
• Consent must be specific for SMS, general language including “opt into communications” is not considered sufficient (instead say “opt into receiving SMS)
• Businesses that already ask Consumers to sign forms or submit contact information can add a field to capture the Consumer’s consent
• Consent must be logged as outlined below

Message Senders Should Provide Clear and Conspicuous Calls-to-Action

Purpose: Disclosure to ensure that a consumer consents to receive a message and understands the nature of the program

• Invitation to opt-in to a messaging campaign
• Calls-to-Action should not contain any deceptive language
• Calls-to-Action should not be obscured in terms and conditions
• Example of calls-to-action:
  • The program or product description
  • Telephone numbers or short codes from where the message will originate

Ways to Collect Opt-in

Purpose: Help prevent messages from being sent to a phone number that does not belong to the Consumer who provided that phone number (e.g., a Consumer purposefully or mistakenly provides an incorrect phone number to the Message Sender)

For conversational messages:

• Recipient sends you a message first

For informational messages (and conversational):

• Verbally asking recipient if they would like to receive messages
• Clicking a button on a mobile webpage

For promotional messages (and above):

• Entering a telephone number through a website
• Turning on SMS notifications via a website preferences panel
• Responding to an ask, or asking to be sent SMS via email
• Sending a message from the Consumer’s mobile device that contains an advertising keyword
• Signing up at a point-of-sale (POS) or other Message Sender on-site location
• Opting-in over the phone using interactive voice response (IVR) technology

.

Logging Consent:

Purpose: to provide clear evidence that a recipient has opted in to messaging, critical for promotional messages. Carriers may request this information to be provided randomly.

Message Senders should also document opt-in consent by retaining the following data where applicable:

• Timestamp of consent acquisition
• Consent acquisition medium (e.g., cell-submit form, physical sign-up form, SMS keyword, etc.)
• Capture of experience (e.g., language and action) used to secure consent
• Specific campaign for which the opt-in was provided
• IP address used to grant consent
• Consumer phone number for which consent to receive messaging was granted
• Identity of the individual who consented (name of the individual or other identifier (e.g., online user name, session ID, etc.)).

so if you only respond to texts and NEVER do outbound campaigns, do we need to register or what does this mean? Thank you in advance.

It's a garbage hand that is being dealt to any SaaS provider involved in texting.
RC is not alone, but while I understand they have to deal with this, they by no means are they early to this issue. They are woefully late. The first deadlines were actually in Nov/Dec. The deadlines keep getting pushed back and are just now coming to a head.

A few facts* that have surfaced:

*The facts are changing all the time on A2P 10DLC registrations. Anyone that knows anything is probably out of date by next week.

Most alarmingly - There is (too) quiet concern regarding the ownership of TCR. (China) https://www.marketscreener.com/quote/stock/KALEYRA-INC-54264487/news/TCR-Acquisition-LLC-Makes-Formal-Offer-to-Acquire-100-of-The-Campaign-Registry-from-Kaleyra-Inc-40963336/

I tried writing my congressman on this... but they are busy with nonsensical issues that don't impact real people or business.

More so: Two major US carriers are driving this harder than anyone - T-Mobile and AT&T.
Don't like this? Tell them. (This isn't RC's fault)

The threat of $10 fines (T-Mobile) per unregistered message is understandably enough to make Ring Central justified in stopping unregistered traffic. To not, would mean unsustainable risk in a non-neutral playing field.

We can all agree - the threat of fines and filtering on legitimate businesses hardly feels like a solution to prevent bad players from playing badly. It only punishes the good guys and does nothing to solve Spam issues.

In the end - I know nothing. All I really see is this.

- Businesses need to pay more to text.
- We have no choice but to send our data to (TCR) which has ties to the Peoples' Republic of China, while.... (and this is key)

- Carriers make more money to 'keep people safe' from spam.

I'm not a fan of how RC is managing this. But I can tell you confidently RC makes no money on this. It is only headache, heartache, pain and stress. I'm sympathetic for anyone that works in this space and is caught in the middle between angry clients that don't know and carriers that don't care.

Meanwhile... the FCC lags, and our US representatives argue about whether or not to ban TikTok... We're doomed... aren't we?

Cheers.

Craig O'Neill wrote:

I tried writing my congressman on this... but they are busy with nonsensical issues that don't impact real people or business.

I love you.

We can all agree - the threat of fines and filtering on legitimate businesses hardly feels like a solution to prevent bad players from playing badly. It only punishes the good guys and does nothing to solve Spam issues.

Marry me.

Going to have to put disclaimers on our page indicating issues with SMS to our customers. Big problem is a significant amount of our customers do not have/use email and this is going to harm business.