As a reminder, The Campaign Registry (“TCR”) continues to be mandatory for telephone numbers that are routed through a virtual phone service provider (“service provider”). The goal of TCR registration is to prevent spam and other unwanted messages from being delivered to consumers. Only after approval by its service provider, will a company’s 10-digit long codes (“10 DLC”) be registered with major mobile carriers. TCR registration helps ensure that text messages originating from company long codes will not be blocked or delayed.
As our readers are aware, TCR registration is a comprehensive and arduous process. Companies can help speed up the approval process by ensuring that certain information is ready for submission during the registration process.
What Information Will Service Providers Review During the Registration Process?
Prospective TCR registrants will need to provide certain basic company information on the long code registration form, including, but not limited to:
Companies should also ensure that their consumer-facing websites are operational and accessible. Among other things, service providers will use websites to examine a company’s: 1) Privacy Policy; 2) Terms of Service; 3) SMS consent opt-in language; and 4) “About us” or “Contact us” information page (at a minimum, a website must disclose the company’s business name, address, and phone number).
Legal Counsel Can Assist With Troubleshooting Long Code Registration Issues
The TCR registration process involves many steps and regular interaction with service provider representatives. Frequently, companies will be repeatedly notified that long code registration was rejected for a variety of reasons. For example, some applications may be rejected because they include proposed text message content of a nature that is strictly prohibited (i.e., gambling, debt collection, or illegal substances). Others may be rejected because the subject Privacy Policies do not meet TCR standards (i.e., Privacy Policies must be hosted on the same domains as business websites and explicitly state that personally identifiable information will not be shared with third parties). Whatever the reason, being unable to contact consumers using long codes hurts the bottom line.
Retaining experienced counsel to work with your company will help expedite the TCR campaign registration process. The attorneys at Klein Moynihan Turco provide clients with TCR registration assistance, regularly reviewing their proposed campaign content and preparing related customer opt-in language, Privacy Policies, and Terms of Service.
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