Don’t completely panic about P2P texting yet, I did use the word “could” for a reason. That being said you should be prepared for anything. The CTIA, the industry association and regulatory body for the mobile carriers (At&T, Verizon, TMobile, et al) is signaling that all private entities, which includes campaigns and nonprofit organizations need to register their “brand” and/or campaign for any 10DLC or longcode use. Originally 10DLC (10-digit long code) was thought to be a separate message delivery product, but now it appears all longcode (ie. local phone number) usage is being lumped into that category and could require an opt-in.
What is A2P 10DLC (Application-to-Person via 10-digit long code)?
It is a program that is being implemented by the mobile carriers to support SMS/MMS message delivery that originates from an application and not another handset (P2P). This is their way of preventing spam or “unwanted messaging” and makes it easier to hold senders accountable.
The important thing to note is that the CTIA defines P2P texting (peer-to-peer) very differently than those of us in the nonprofit & political world. The Federal Communications Commission (FCC) doesn’t even really define texts as A2P or P2P, they simply look at whether the platform or technology used to send the messages can be classified as an auto-dialer. A court decision in the Summer of 2020 made clear that P2P texting as we know it is not an auto-dialer and not held to the TCPA mandatory opt-in regulations. Which is great! But, the problem is that there is nothing stopping the carriers and the CTIA from enforcing their own rules.
CTIA Messaging Principles and Best Practices define A2P and P2P differently than the FCC:
- 3.3.1 Consumer (P2P) A Consumer is an individual person who subscribes to specific wireless messaging services or messaging applications. Consumers do not include agents of businesses, organizations, or entities that send messages to Consumers.
- Volume is typically less than 1,000 messages sent or received daily.
- Throughput 15-60 messages sent per minute.
- One phone # assigned to a single consumer.
- Less than 100 unique recipients (10 is the average).
- No more than 35 repetitive messages.
- 3.3.2 Non-Consumer (A2P) A Non-Consumer is a business, organization, or entity that uses messaging to communicate with Consumers. Examples may include but are not limited to, large-to-small businesses, financial institutions, schools, medical practices, customer service entities, non-profit organizations, and political campaigns.
Based on the CTIA definition, any mass texting from an organization or entity, even if one-on-one from an “agent,” without an auto-dialer, is considered “Non-Consumer (A2P).” Some of the aggregators (Twilio, SignalWire, YTel, etc.) have begun alerting their customers of the need to register campaigns via the “Campaign Registry.” Some of those aggregators have set up forms to go through them to register. These forms have similar questions to a shortcode application (5-6 digit # for A2P messaging) and require proof of an opt-in process.
If all long codes (ie. local #s) are being defined as 10DLC, and all 10DLC users must register brands and campaigns with a clear opt-in — this means that cold P2P texting from a local number without an opt-in will cease to exist.
There are still more questions than answers on how exactly this will be implemented long term. 10DLC is being rolled out throughout 2021, and the Mobile Carriers (AT&T, Verizon, T-Mobile, and others) will be implementing their own specific version(s) of A2P 10DLC. AT&T is the first to announce the implementation of their A2P 10DLC program for SMS which becomes effective March 1, 2021.
Is there another way?
An alternative to A2P 10DLC is to register and use a Toll-Free Number (TFN) for P2P texting campaign delivery since it appears to not be impacted by these changes. There is also a chance that P2P as we know it could be classified under “Group Messaging:”
6.1 Group Messaging
Depending on the specific implementation, group messaging might utilize phone numbers that are typically not assigned to a unique individual, and their characteristics may be inconsistent with Consumer (P2P) messaging. Therefore, depending on the particular characteristics of a service, Service Providers may require special arrangements to facilitate group messaging phone numbers (e.g., similar to Non-Consumer (A2P)), such as the identification of group messaging phone numbers. It is recommended that group messaging services:
- Have strong anti-abuse controls and mechanisms appropriate for systems with potentially large message distribution;
- Support the ability of any member to opt-out of the group at any time; and
- Employ mechanisms to prevent recursive group messaging and cyclical messaging involving more than one group (e.g., in which one group is a member of another group).
But, we don’t really know what “special arrangements” will look like, and whether nonprofit and/or political organizations might be provided with any special allowances.
The other major change with 10DLC is the implementation of a new Network Access Fee (NAF) for all text messages sent to their subscribers. The NAF fee will range from $0.004 to $0.002 per message. This fee will be passed along to the entity sending the messages. There are also one-time and monthly fees associated with a brand and campaign registration.
- A one-time registration fee, per brand, of $10.00
- A recurring monthly fee, per campaign, of $15.00 (decreases depending on the use case – nonprofits pay $5 per month)
Additional fees and surcharges are expected as the other mobile carriers bring their A2P 10DLC programs online. We will provide additional information as it becomes available. A grace period will be allowed until June 1, 2021 for unregistered campaigns and their messages to be delivered, at the discretion of the mobile network operators.
Smart As A Fox will continue to keep progressives in the nonprofit and political spaces updated on these changes as they are still ongoing and developing.
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