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Toll-Free Messaging Verification

In an effort to reduce spam and tackle fraud, mobile carriers are now requiring businesses that send SMS messages to register their Toll-Free Numbers (TFN’s). The enforcement for the 10/1/2022 deadline has changed from failing all unverified Toll-Free traffic to failing traffic that exceeds 2000 messages per day per number. Unverified TFNs will have their message volumes limited and spam filtering will be more aggressive. According to the messaging aggregator, this part of the process is to verify all Toll-Free numbers and align sender visibility with the Short Code and 10DLC messaging channels. They recommend verification on TFNs as soon as possible to avoid these daily limits.

When will Toll Free Verification be implemented?

May 15, 2022 Effective May 15, 2022, the Toll-Free Messaging Aggregator is requiring all new Toll-Free Numbers (TFNs) to complete the toll-free verification process.
October 1, 2022 Numbers that are in-market today but are not verified will need to complete the verification prior to September 30, 2022.  After this Sept. 30 deadline, unregistered numbers will be subject to a more aggressive spam filtering and messages above usage thresholds will be blocked.
October 1, 2022 Effective October 1, 2022, unverified traffic destined to Canadian numbers will be blocked.

 

To avoid limits on your message volume and this aggressive filtering, you will need to submit each TFN for registration. Once your numbers are registered, your business TFN and use case will be approved for messaging to the US and Canada.

No API has been available for submitting Toll Free Verification requests, however we are beginning to hear news that this is under development.  The messaging aggregator intends to continue with manual registration for the time being.  Consequently, our Support Team is handling all submissions manually.

Are there any fees to register my toll-free numbers?

There is no additional cost associated with this registration and no campaigns to assign.

Toll Free Business Messaging Thresholds

Effective October 1, 2022 for unverified Toll-Free numbers, the messaging aggregator will apply the following industry-wide thresholds:

  • Daily limit: 2,000 messages
  • Weekly limit: 12,000 messages
  • Monthly limit: 25,000 messages

Also beginning October 1, verification is required for all Toll-Free numbers when sending traffic to Canada. Unverified traffic destined to Canadian TNs will be blocked – the limits mentioned above only apply to traffic destined to U.S. TNs. Once a TFN is in a pending state, these blocks no longer apply.

The messaging aggregator notes that these thresholds are subject to change and they will announce threshold changes at least 30 days in advance.

What happens if I don’t complete the verification?

On October 1, 2022, messages sent from unverified TFNs will be restricted to the messaging limit. If the limits are exceeded, messaging traffic will be strictly filtered or blocked. These messages will be exposed to the strongest industry spam filters (verified numbers go through less spam filtering).

Your first reaction to this might be “Not a problem, we don’t send spam.”  But anyone that has installed anti-spam software has experienced those frustrating false-positives where a legitimate message is incorrectly identified as spam. Having your legitimate communication with your customers or employees be filtered or blocked could severely hamper your operations.

If the outgoing messaging volume on your TFN increases, or if the messaging aggregator lowers the limit thresholds, messaging could be blocked without warning. It would require careful monitoring of messaging volume and the industry thresholds on unverified TFNs to avoid a problem.  Often we don’t realize there is a delivery problem until a customer reports that their end users are not receiving messages.

If your TFN begins experiencing delivery issues, it won’t be a quick fix — currently, it is taking 3 to 6 weeks to complete each TF Verification request. (Note there is a serious backlog in verification submissions as of this article date, but it is expected to improve.)

We highly recommend that you register your TFNs in order to ensure the best possible service. Especially for your TFNs that have a higher volume messaging output or where messaging is critical to their business operations, like appointment reminders, service alerts, employee communications, etc.

How do I submit my TFNs for verification?

We will be reaching out to our customers individually to discuss their toll free numbers, SMS usage and the messaging thresholds. If you have any questions or want to proactively register your Voice Elements/Inventive Labs toll free numbers, please contact our Support Team.

Tips to Facilitate Approval of your TFN Verification

Submitting your TFN for verification is a simple process and the information you provide is pretty basic.  However, we have found that the point where we see significant delays in the verification process revolves around the Opt-In description and documentation.  So here are some tips!

The Importance of Your Opt-In Flow

An integral part of the approval process is effectively describing your opt-in flow. Be prepared to describe the process you use and provide documentation of your opt-in flow.  Documentation is required for all use cases. The carrier will not submit the verification request to the messaging aggregator until the Opt-In flow description and documentation meets with their approval.

Opt-In Consent

The Opt-In process involves getting permission or consent from the receiver before sending a business text. A disclaimer in your terms and conditions does not qualify.  Third party opt-in is discouraged. The industry is now setting standards for a direct opt-in for business communication.  Make sure you can demonstrate that you receive the appropriate consent level for your use case.  Use the Double Opt-In method when in doubt.

What level of consent do I need?

While the industry recognizes three types of consent levels, for Toll Free Verification, you must choose between Informational and Marketing.  If your messaging falls within the Conversational definition, you would choose Informational.  Be sure to clearly explain who you communicate with in your Use Case Summary, as communicating to existing customers or employees does not require a higher level of consent.

Conversational Messaging

Conversational messaging is a one-on-one two-way conversation between you and your existing customers, employees, or known contacts with an existing business relationship.  It is implied that a customer wants a response when they initiate a text to a business with a request for information.  This is considered implied consent; however it is a passive opt-in (a weaker consent level) rather than a direct opt-in. Because you are communicating with individuals you have an existing business relationship with, implied consent is adequate. Often with appointment reminders, consent is requested within new patient paperwork–an excellent form of direct consent.

When a consumer (who is not an existing customer) initiates the communication, no further consent is required if the business only replies to that one specific request. To contact the consumer again, there must be express consent.

Informational Messaging

Information messaging is when a consumer supplies your business with their phone number and asks to be contacted in the future.  This could be a one-way alert or a two-way conversation about the information requested.  The consumer must agree to receive the texts when they give a business their mobile number.  The business needs Express Consent (oral or written)  to provide the information to the consumer. The Double Opt-In is an easy way to confirm their express consent.

Promotional Messaging

Promotional messaging contains marketing or sales information and may include a call to action.  Any promotional messaging requires Express Written Consent which involves them signing a form, checking a box online, etc. expressly stating that they consent to receiving promotional text messages.

What is a Double Opt-In?

Double Opt-In is not required yet in business SMS, nor is it required to successfully register your TFNs; however, the industry is stressing their desire for all businesses to get double opt-in confirmation during the initial SMS conversation. Since we began submitting these Toll Free Verification requests, we have been seeing less kick-backs and delays when a Double Opt-In flow is in place, especially if a screenshot of that messaging flow is provided.  Here’s how it works:

Upon receiving the initial text from the customer, the business replies asking the individual to consent to the opt-in with Yes.  Rather than a sterile legal consent, consider it more like a friendly Welcome Message that thanks them for reaching out and asks them to please reply YES for consent.  Here are a few examples:

  • “Thanks for signing up for our text alerts. We’d like to confirm that you want to receive texts from [business name]. Reply YES to confirm.”
  • “Hi, this is [business name] following up with you on your request for information. Do you agree to receive texts from us?”
  • “Welcome to the [business name] team!  We send employee reminders and alerts as explained in our hiring paperwork. Please consent to employee notifications by replying YES.”

After receiving consent, you’ll naturally program a Thank You response. This is the perfect moment to add ‘Text STOP to unsubscribe’.

If the response to your Opt-In confirmation is NO, that is an Opt-Out.

The Opt-Out

At this time, the Opt-Out flow is not necessary for your Toll Free Verification.  Be aware that high volumes of Opt-Outs can impact your deliverability.  When message senders notice high volumes of opt-outs, this sends a red flag indicating poor messaging standards or lack of opt-in. Developing proper Opt-In and Opt-Out procedures will help ensure your message deliverability.

Your STOP notification could be a keyword like REMOVE, UNSUBSCRIBE, QUIT, OPT-OUT, CANCEL, etc.  Unusual STOP keywords are interpreted as an attempt to make the Opt-Out difficult (a serious red flag), so we recommend that you keep it simple and use STOP.  You do not have to include your Opt-Out language with every text you send, but consumers like to be reassured they always have the option.  At the very least, we recommend that after you receive the initial Opt-In consent and reply with your welcome message, that you include your Opt-Out language.

Honor every Opt-Out request.  Upon receiving the message to STOP, we recommend that you reply with an Opt-Out confirmation message explaining that all texts from this number are now blocked, and provide an UNSTOP option to receive messages again.  No further communication is allowed until new consent is received.

What are some examples of a Proof of Opt-In?

For your Toll Free Verification, be prepared to provide a screenshot or other documentation of your opt-in flow in addition to the description. Here are some examples:

      • Website opt-in: Screenshots of the webform where the client adds their number and agrees to receive messaging.
      • Website Posting (Support): Provide image or screenshot showing where the number is advertised and where the customer finds the number to text in.
      • Keyword or QR Code Opt-in: Provide image or screenshot showing where the customer finds the keyword in order to opt-in to these messages.
      • Voice/IVR Opt-In: In this case please provide a screenshot record of opt-in via voice in clients database/ CRM. (IE, a check box on their CRM saying that the customer opted in and the date)
      • 2FA/OTP: Provide the screenshot process to receive the initial text.
      • Paper form (Customer/ Employee): Please provide an image of the form.

Use Case Categories and Sample Messages

You will select one use case category for your TFN.  Note the eligible and ineligible use cases below.  The sample messages that you will provide will reflect your use case category.

Eligible Use Cases

2FA
App Notifications
Appointments
Auctions
Auto Repair Services
Bank Transfers
Billing
Booking Confirmations
Business Updates
Career Training
Chatbot
Conversational / Alerts
Courier Services and Deliveries
COVID-19 Alerts
Emergency Alerts
Events and Planning
Financial Services
Fraud Alerts
Fundraising
General Marketing
General School Updates
Healthcare Alerts
Housing Community Updates
HR / Staffing
Insurance Services
Job Dispatch
Legal Services
Motivational Reminders
Notary Notifications
Order Notifications
Political
Public Works
Real Estate Services
Religious Services
Repair and Diagnostics Alerts
Rewards Program
Surveys
System Alerts
Voting Reminders
Waitlist Alerts
Webinar Reminders
Workshop Alerts

Ineligible Use Cases

High-Risk Financial Services Get Rich Quick Schemes Debt Forgiveness Illegal Substances/ Activities General
Payday loans
Short-term, high-interest loans
Auto loans
Mortgage loans
Student loans
Gambling
Sweepstakes
Stock alerts
Cryptocurrency
Debt consolidation
Debt reduction
Credit repair programs
Deceptive work from home programs
Multi-level marketing
Work from home programs
Risk investment opportunities
Debt collection or consolidation
Cannabis
Alcohol
Tobacco or vape
Phishing
Fraud or scams
Deceptive marketing
Pornography
Profanity or hate speech

When will my TFN be SMS enabled?

We can enable SMS on your toll free number immediately for messaging in the US, however it then becomes subject to usage thresholds and aggressive spam filtering.

Due to message blocking to Canada for unverified TFNs, your number will not be SMS enabled until it is in Pending Verification status.  Voice can be enabled immediately.

Pending Verification Status

After we submit your TF Verification request to our carrier, they evaluate the submission and respond for more information or clarification as needed. Once they resolve any issues, they submit it to the messaging aggregator where it is assigned a status of Pending Verification.

Our carrier has assured us that the aggregator will not apply usage thresholds or aggressive spam filtering on any Toll Free number with a status of Pending Verification.  Additionally, messages to Canada will not be blocked while in pending status.

Questions or Concerns?

If you have questions or concerns about Toll Free Verification and the possible impacts on your messaging service, please contact us at support@inventivelabs.com.

Messaging Industry Resources

CTIA Messaging Principles and Best Practices
https://api.ctia.org/docs/default-source/default-document-library/170119-ctia-messaging-principles-and-best-practices.pdf

MMA Best Practices
https://www.mmaglobal.com/taxonomy/term/2820

M3AAWG Best Practices
https://www.m3aawg.org/sites/default/files/m3aawg-mobile-messaging-best-practices-service-providers-2015-08_0.pdf

Telephone Consumer Protection Act (TCPA) Omnibus Declaratory Ruling (FCC 15-72)
https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.pdf

FTC Truth in Advertising
https://www.ftc.gov/news-events/media-resources/truth-advertising

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