10DLC and P2P Text FAQ

10DLC and P2P Text FAQ

The top-line? You can keep texting (including “cold”) but the future is uncertain. Want more details? That’s where things start to get confusing.

 

Read on to learn more and we’ll do our best to keep this up to date. 

 

[Revised September 28, 2021]

What is 10DLC?

Can I text contacts without “opt-in” on 10DLC?

But Twilio, Hustle, or other services I use say I can’t text without opt-in. Can I?

Why isn’t there anything in writing saying I can cold text then?

Should I be worried that my trust score will get destroyed by sending cold texts?

Are my texts going to start getting filtered more now?

Should I be worried about throughput limits?

Should I include “STOP to opt-out” in my texts?

My lawyers are making us shut down our texting operation! What do I tell them?

What information do I need to register my brand?

We’re a small organization sending less than 3,000 texts/day. Do I need to register my brand/organization?

Are there fines or fees if my organization does not register?

What are throughput caps and how does it affect our organization?

Is 10DLC legal? Is this really happening?

 

What is 10DLC?

Wireless carriers, including AT&T, Verizon, and T-Mobile, are trying to force traffic generated by organizations to register as a way to prevent illegal, malicious texting by connecting senders to specific numbers.

10DLC stands for 10-Digit Long Code, referring to the local phone number used to launch texting campaigns. Wireless carriers are pushing all entities, which includes nonprofits, campaigns, and 527 political organizations, to register their brand through the Campaign Registry for texting campaigns using long-codes.

Although we can still send texts outside of 10DLC-registered numbers, we’ve found that the results are 10-20% better when sending from 10DLC-registered numbers, so we recommend clients do so when possible.

 

Can I text contacts without “opt-in” on 10DLC?

Yes, you can. The issue is that texting with prior consent (“warm”) is a Cellular Telecommunications Industry Association’s (CTIA)’s — the wireless carrier industry association — best practice. But it doesn’t appear in any of the proposed fines and fees or new rules for 10DLC. We can still text “cold” contacts through 10DLC, but if those texts are blocked, we’ve seen carriers request proof of opt-in. The requirements to “prove” opt-in are very specific, so if our clients aren’t able to jump through those hoops, we send their texts unregistered.

 

But Twilio, Hustle, or other services I use say I can’t text without opt-in. Can I? 

While you can text, your service provider (“aggregators”, like Twilio and Bandwidth, or further downstream service providers like Hustle and Movement Labs) may tell you texting without opt-ins isn’t allowed. They are saying that they are choosing to follow the CTIA’s best practices. That’s fine for them, but if you are trying to reach unregistered voters, or encourage people to get a vaccine, or crush fascism via SMS, you may want to find another provider. Whether you want to use us or someone else, we can help with that.

 

Why isn’t there anything in writing saying I can cold text then?

In back-door conversations, senior folks at the relevant aggregators and carriers have said that political messaging is not being targeted. Carriers are very afraid of facing negative publicity for the 10DLC roll-out. BUT, they are more concerned that publicly giving a “nod” to cold texting would create a world where businesses and malicious actors start to go wild.

 

Should I be worried that my trust score will get destroyed by sending cold texts?

There’s been little communication about what would negatively impact a trust score from the carriers or Campaign Registry, but it’s fair to assume that spam complaints or opt-out rates might do that. If you’re concerned about that, we are actually providing a service to folks to let them continue running their texts under OUR trust score. We’re taking on the risk for you, as long as you meet some basic conditions.

 

Are my texts going to start getting filtered more now?

It’s really hard to say definitively. Folks at or close to the carriers have basically said if you haven’t been getting blocked in the past you won’t start to. We’ve found that text deliverability is generally 10-20% better when sending from 10DLC-registered numbers, compared to unregistered traffic. However, 10DLC registration will not make your texts immune to potential spam blocks.

Because carriers don’t give accurate reports of which messages they are filtering, a good approach to answer this question is to create a very large pool of people that you’ll text over many months. If you keep sending the same texts on a regular basis to a similar universe of people and see your response rate shift from a single carrier’s contacts, you are detecting filtration. We’re happy to share more about what we have learned on a call with you.

 

Should I include “STOP to opt-out” in my texts?

During the 2020 election, there was a buzz that everyone needed to include this language in their cold texts. We tested this extensively. Results proved it didn’t help with filtration at all. It simply spiked our opt-out rates. We haven’t seen anything that suggests you need to include this language, but we’ll be continuing to test in 10DLC.

 

My lawyers are making us shut down our texting operation! What do I tell them? 

Oh man, that really sucks. First off, you can tell them that two big developments have moved texting liability out of the legal arena and push back hard on them because of that. 

You can remind them that Facebook vs. Duguid removed TCPA liability for texting and that the FCC recently redefined texting as an “information service”, rather than a “communications service” removing their jurisdiction over the issue. Those two things mean that the potential risks of texting aren’t legal, but they are related to fines and fees threatened by the carriers, or the terms of service in your texting provider. 

If your lawyers aren’t interested in backing down, talk to us about signing a contract to take on your legal liability to make them comfortable. That’s right – Movement Labs is committed to helping progressive partners continue texting so much we are willing to pay any fees, legal or otherwise, that might arise in the course of your texting. Talk to us!

 

What information do I need to register my brand? 

Here’s what you’ll need in order to register your brand for texting:

  • Legal Company Name
  • DBA or Brand Name (if different from legal name)
  • Country of Registration
  • What type of legal form is the organization?
  • Tax Number/ID/EIN
  • Address
  • Website
  • Vertical/Industry Type that best describes your organization. 
  • Contact Information: Email
  • Contact Information: Phone

Your texting service provider (like us) should help you register, or you can use Twilio or another aggregator, or you should be able to go directly to The Campaign Registry. 

If you are a federal 527,  local, state, or national political campaign, candidate or committee then you’ll also be heading to Campaign Verify to get a “token”. To get that token, you’ll need the individual listed on the FEC or other publicly available campaign finance filings to move this forward.

 

We’re a small organization sending less than 3,000 texts/day. Do I need to register my brand/organization? 

If your organization does less than 3,000 texts per day, and you are not using more than five (5) phone numbers to send those texts, you are not required to register your brand at this time.

 

Are there fines or fees if my organization does not register? 

There are some scary-looking fines! Specifically “evasion” and “text enablement” should scare anyone looking closely. Evasion is $1,000 but our sources have said it is only related to texting you REGISTER on 10DLC – essentially if you’re using lots of campaigns/phone numbers on 10DLC to avoid spam filters, they will be unhappy with you. Text Enablement looks like it refers to sending unregistered traffic, but according to our sources, this fine relates to systems much further in the back-end of sending texts that long pre-date 10DLC. To actually get texts sent, you need an ID with the carrier, and this fine applies if you don’t get the required verification before using that ID to send messages.

T-Mobile and AT&T have both implemented a small surcharge fee per unregistered SMS segment, $0.001 and $0.002 respectively. Other vendors may price you differently for registered texting and unregistered texting. However, Movement Labs does not charge our clients extra for sending unregistered messages.

 

Should I be worried about throughput limits?

Carriers have started to implement throughput limits based on brand types and campaign use types, listed below. Clients who receive a low vetting score may not be approved to send their intended volume of daily texts. For this reason, many of our clients who received brand scores of less than 75 have opted to continue to run their texts on unregistered channels. If you got a low vetting score (this used to be called “Trust Score”), then you may want to talk to us about texting unregistered or under our Brand ID umbrella, which is 75.

 

What are throughput caps and how does it affect our organization?

Throughput caps are the amount of text messages a particular brand can send daily (or per second to ATT phones). See the chart below for more information on what your type of organization should expect.

 

Campaign Use Case Eligible Org Types AT&T MPS Verizon MPS T-Mobile MPS T-Mobile Daily Caps
Standard All 1-60 (Depends on Trust Score) 1-60 (Depends on Trust Score) 1-60 (Depends on Trust Score) 2k-200k

(Depends on Trust Score)

Emergency All 75 75 75 2k-200k

(Depends on Trust Score)

501(c)(3) / Charity 501(c)(3)s 40 40 40 2k-200k

(Depends on Trust Score)

Political 501(c)(4), 501(c)(5), 501(c)(6) 75 75 75 2k-200k

(Depends on Trust Score)

527s, reporting entities 75 75 75 Unlimited

(CV Token Required)

 

Is 10DLC legal? Is this really happening?

Even though the carriers are saying privately “don’t worry, we aren’t targeting political texting”, they are taking steps that would allow them to easily stop us from organizing or censor us – and some of the vendors they’ve engaged are actually connected to the Trump campaign!

The same FCC move that shifted texting away from their jurisdiction essentially gave carriers all the power to regulate texting and generate profits from it. State Voices, Movement Cooperative and MoveOn are leading the Coalition for Open Messaging which is advocating against these changes and to protect texting.

We need to build power to be able to fight back and credibly threaten legislative action or FCC regulation if the carriers go too far or treat our organizing work unfairly. Join the Coalition to help us build that power.

Movement Labs
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