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mary-community-moderator posted Bright Pine Behavioral Health commented

Questions about TCR/Restrictions for Business SMS? The Community wants to hear from you!

Today, 1/11/2022, our customers received an email about The Campaign Registry and new restrictions on business SMS traffic.

We wanted to create a space for discussion and questions about this topic.

The highlights of these changes are as follows:


  • In 2021, mobile carriers imposed new restrictions on business SMS traffic sent from text-enabled phone numbers, known as “10DLC” - 10 Digit Long Code, in line with industry requirements set out in the CTIA’s (Cellular Telecommunications Industry Association - the trade association representing the wireless communications industry in the United States) Messaging Principles and Best Practices.


  • The mobile carriers have extended these restrictions to all business SMS, including conversational texting. All customers using SMS must now self-register with The Campaign Registry (TCR) or their SMS traffic will be blocked by the mobile carriers.


  • To simplify this process, RingCentral will be adding the ability to self-register inside the Admin Portal. We expect this feature to be available on February 10, 2023, at which time we highly recommend you register. Please note carriers and TCR impose registration and other fees. Read more about these fees here.


NOTE:

After March 31, 2023, SMS will be automatically disabled for all existing numbers that have not been registered. If you have already registered via the manual PDF form process, your registration will automatically be added to the admin portal for you to manage moving forward. You can learn more about these changes here.


RingCentral is making every effort to support our customers using SMS, as we react to constantly changing requirements from the mobile carriers over which we have no control.

If you have any questions, please share them here and we will be happy to point you in the right direction.

As usual, the Community Team is here to help - please don’t hesitate to share your questions and concerns in this thread.

sms and text messagingnews and announcements
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Daniel Warns avatar image Daniel Warns commented ·

So far, I keep reading comments from RingCentral employees that this is required, but almost no links are provided to cite this. The few links I have seen are to a Forbes article that doesn't cite it's sources, links to other RingCentral Articles, statements that the FCC requires it, or statements that it's what The Campaign Registry is requiring. All of that being said, this doesn't seem to be accurate to what I've found.


Based on what I've found, the FCC ruling from June 25th, 2020 deemed that businesses that aren't using autodialers or automated messaging services (A2P) are considered P2P and aren't subject to TCPAs restrictions.


The Campaign Registry states at the bottom of the page that it "requires Users to follow industry best practices according to the CTIA".


When examining CTIA, section 4.2, Paragraph 2, states that the designation may depend on whether our messaging traffic satisfies the attributes of Consumer P2P messaging described in section 4.1. I know that myself, and I'd assume many business users would fall under this definition, which would allow us exemption from the registration as we should be assigned as P2P and not A2P.


My conclusion so far, is that RingCentral is making a mistake and going far beyond what the FCC or The Campaign Registry require, by forcing all of it's clients to register as A2P, including the ones that would correctly be labeled as P2P


If you have any links to newer regulation than what I've found, and not just to other articles I'd greatly appreciate it.

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Daniel Warns avatar image Daniel Warns Daniel Warns commented ·

@ringcentral I still haven't heard from anyone about my question above, but for ease, I've included a picture of the CTIA that The Campaign Registry cites as it's governing document, with the primary section in question highlighted. Again, this doesn't include the 2020 FCC ruling that dictated that human made/sent texts, that don't use an automated system are classified as P2P and therefore not subject to the TCPAs restrictions, which is what the CTIA is based on. Please show me where in this document or another release by the phone companies, not a link to your own article that has no links/citations, where it says that all business SMS is P2P (because it's not in the FCC regulation or the CTIA).screenshot-19.png

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David Carson avatar image David Carson commented ·

The only thing I ever use SMS for is receiving 2-factor authentication codes from web sites. I never, ever send SMS messages. If I don't register, will I still be able to receive?

4 Likes 4 ·
Sean Sands avatar image Sean Sands David Carson commented ·

I have the same question -- and I hope someone will answer, though based on what I've seen so far, I suspect the answer is "No, so deal with it." This strikes me as a ridiculous effort to police SMS spam that is at least a decade too late and will, of course, negatively impact companies who use providers like RC. Good grief.

1 Like 1 ·
bobsawyergcm3082 avatar image bobsawyergcm3082 commented ·

We do not send SMS messages - at all. We *receive* them but only for MFA (multi-factor authentication) purposes from client sites where we must login and confirm identity. If we're not sending, why do we need to register?

4 Likes 4 ·
Wayne Sherman avatar image Wayne Sherman commented ·

"The mobile carriers have extended these restrictions to all business SMS, including conversational texting."

"Conversation texting" is a message type that is defined for Non-Consumer A2P (Application to Person). We are not using A2P or automated SMS o bulk SMS in any form. All of our SMS message usage is person to person. According to the above reference CTIA Messaging Principles and Best Practices our SMS use falls under "Consumer (P2P) Messaging":

"Consumer (P2P) messaging is sent by a Consumer to one or more Consumers and is consistent with typical Consumer operation (i.e., message exchanges are consistent with conversational messaging among Consumers), as described in Section 4.1.1."
(see PDF page 10 referenced above for more info)

Since "Consumer" SMS does not require registration, can we continue to use our RingCentral phone numbers to receive SMS texts without registering?

3 Likes 3 ·
Mike Stowe avatar image Mike Stowe ♦♦ Wayne Sherman commented ·

In 2021 mobile carriers reclassified all non-mobile carrier originating business SMS traffic as 10DLC A2P. Unfortunately, for businesses P2P messaging (and the rules associated with it) no longer exist.

As such, all businesses must comply with A2P SMS rules regardless of how they are using SMS.

https://www.forbes.com/sites/forbestechcouncil/2022/07/05/read-this-if-your-business-uses-text-messaging/?sh=18386d70a576

1 Like 1 ·
Wayne Sherman avatar image Wayne Sherman Mike Stowe ♦♦ commented ·

Treating casual SMS users the same as bulk and automated (A2P) users is insane. The language used by CTIA does not even fit what they are trying to apply it to. "Application-to-Person" SMS are automated software systems for sending SMS messages but they are treating that the same as person-to-person SMS. A text message conversation between two persons does not constitute a "Campaign".

Basically ALL business in the US would be required to register in case ANY OF THEIR EMPLOYEES happens to text another party in the course of their business (unless you happen to be using a major carrier for your phone service).

This looks like a money grab from the phone carriers:

1) If you sign up with them directly you don't have to register.

2) They get a huge database of business contacts.

3) They have a bunch of new revenue sources.

4) And if you happen to not use our service periodically we will even charge you a penalty not sending an SMS to our system. (TMOBILE)

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dixiebee avatar image dixiebee commented ·

Once again, the abusers ruin it for everyone. I have been on the fence about cancelling my RC account for a few years now and this settles it.

RC, if you have lobbyists, now is the time to use them. I am also writing letters to my elected representatives about how this harms normal usage by small business. I suggest everyone else do the same.

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Mike Stowe avatar image Mike Stowe ♦♦ dixiebee commented ·

We understand that this is a significant, and painful change. We will continue to do everything we can to protect our customers, including advocating on our customers behalf and continuing to provide free allocations of SMS to offset the per-message carrier surcharges that were previously implemented.

1 Like 1 ·
Becky-Community_Manager avatar image Becky-Community_Manager ♦♦ dixiebee commented ·

Sorry to hear this.
Unfortunately, @dixiebee this will trickle down to all companies eventually.
From what I understand, RingCentral is ahead of the game and advocating for our customers in advance.
If we can answer any additional questions to support you, please reach out to us here or via email. Community.Support@RingCentral.com

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dixiebee avatar image dixiebee Becky-Community_Manager ♦♦ commented ·

I appreciate you being proactive but I don't appreciate these agencies treating us small business people like crooks and spammers.

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