Last updated June 16, 2023

Overview

‍This page is intended to inform Case Status customers of important developments in the telecommunications industry regarding SMS text messaging (1) to make sure you are aware of what is happening and why, (2) to understand what Case Status is doing on your behalf, and (3) to relay what best practices you can follow to ensure your messages reach your clients. NOTE: This does not affect in-app messaging.

Please note that all SMS providers and all text messages are subject to these new regulations. We take pride to be your client engagement platform and to be your trusted advisor as the industry evolves. We are committed to helping you see the best results when using SMS text to message your clients.

‍What is happening and why
‍If you have a personal smartphone, chances are you have gotten “SPAM” in your email inbox, unwanted calls to your phone number, and unwanted texts to your phone number from unknown entities.  Some of these can be a security concern while others are just uninvited solicitations, but all are bad actors not following good business practices and using technology to reach a lot of people with a single effort.  The good news is society always reacts (sometimes government and sometimes the industry) to set regulations to stop the bad actors.  For example, congress passed the CAN-SPAM Act to address the problem of unwanted commercial e-mail messages. Now proper emailing requires opting-in and having the ability to manage preferences or unsubscribe on every email. The bad news is these regulations introduce change in our business practices, and new behaviors that must be learned, applied and mastered.

For SMS text, the industry is going through a similar change as we speak with a set of self-imposed regulations (from the likes of Verizon, ATT, TMobile, etc.) that is passed to SMS text providers (the likes of Twilio, Vonage, Podium, etc.)  This is called A2P (application to person) texting because a program is initiating communication.  Read here for more about the new industry regulations.  (Link)  Regardless, the bottom line is we as legitimate business providers need to follow some new and evolving best practices to ensure that our SMS messages do not get blocked, or worst case, the phone numbers from whence these SMS messages originate do not get blocked.  The next two sections talk about these best practices.  We will start with what we are doing to help and then segue into what you need to do.

‍What Case Status is doing on your behalf
‍Case Status partners with Twilio, the industry’s leading provider of SMS text applications, to deliver your messages to your client’s smartphone.  Over the past year we have been working closely with Twilio to understand the new regulations and how we can stay in compliance.  These regulations go into effect this summer.  Compliance consists of two main areas: (1) registering originating numbers under legitimate business campaigns from legitimate businesses (i.e. your firm) and (2) following the best practices of what content, language, syntax and characters are used in individual messaging.  As part of the implementation process, we are able to address #1 when setting up your firm with Twilio.  For those of you who were implemented before this summer, we have been working with Twilio to register your company and number with the proper campaign.  This work is material and involves a lot of staff time and energy, but we are happy to represent you in this effort.We need your help to maintain compliance for #2.

‍Best Practices to start implementation ASAP
‍We need your help to ensure message content follows best practices which will ensure message delivery and number integrity.  We are sharing a few of the current known best practices from Twilio and will continue to add to this list as they share with us.  

‍Best practice 1 - Continue to encourage your clients to download the App.  Case Status overall sees adoption in the 75-85th percentile overall.  This is important.  This means that bulk or 1:1 messages do not get delivered via SMS text and thus are not restricted by these regulations.  Instead they get delivered via the app and a push notification alerts the client that a new message is available.  The higher the App adoption, the fewer SMS text messages that are in play.

‍Best practice 2 - Ensure that your standard client terms are available on your public web site.  In those terms be sure to be explicit that by being a client of the firm the person is opting-in to receive text messages from the firm.  In the initial SMS text sent to the client inviting them to the App, include a link to these standard client terms.  This will ensure that Twilio and the carriers have direct access to the public information and agreement between the firm and the client.

‍Best practice 3 - When writing any message from the Case Status platform to the client follow the formatting tips below.  These best practices will distinguish you further from the bad actors.  And remember even if you have a high adoption rate of the App, write the message following these best practices because those clients who have not downloaded the app will get the message via SMS text and you still want it to get through.

‍Formatting your messages (Link):
DO NOT USE URL shortening: Do not send links that have been shortened using shared public URL shorteners, such as TinyUrl or free Bitly links.
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If possible, when sending URLs/links in your messages, use domains that you control.
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Don’t use emojis, or unnecessary special characters/capitalization, and watch your grammar and spelling.  Typically, these messages are structured in a way to attempt to evade detection of unwanted messaging, and your messages will be filtered.
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Forbidden Message Categories (Link):
‍High-risk financial services (certain types of loans, cryptocurrency, etc.)Third-party lead generation servicesDebt collection or forgiveness“Get rich quick” schemesIllegal substances/articlesPrescription drugsGamblingSpeech that mentions: Sex/Hate/Alcohol/Firearms/Tobacco

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‍For more detailed information about what Case Status is doing related to updating campaigns, please read below.

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‍Due to recent regulatory and industry updates to improve trust around the use of application-to-person (A2P) SMS messaging, Case Status firms leveraging SMS messaging are required to register for A2P 10DLC to be able to send text messages. This is required by all major U.S. telecommunications carriers and is not specific to Case Status or our messaging provider, Twilio.

‍Beginning July 5, 2023, all SMS messages sent to U.S. phone numbers using 10DLC phone numbers—i.e., 10 digit US phone numbers such as (555) 555-5555—must be sent via a registered application-to-person (A2P) campaign. Part of the Case Status Implementation process is to register your SMS service as part of a campaign.

Sending messages without registering after July 5, 2023 will subject them to message blocking, ultimately leading to a full block of all U.S.-bound messages sent after August 31, 2023. Case Status works to register all your SMS service via approved campaigns.

Below are details provided so you can better understand the policies and the work effort by Case Status to maintain compliance with the SMS carriers and providers.
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‍Requirements:

1. Your organization must be a registered business with a Tax ID/EIN.

2. You must be able to show through a publicly verifiable source that your authorized representative is an employee of your organization. (E.g., Business social media account, government website, company website, etc.)

3. Your organization must have some type of opt-in consent that SMS recipients register with prior to receiving messages. See below for guidance.

Procedure

‍Registration

There are 3 required steps our team will need to take when deploying your Case Status Solution.

1. Create a business profile (see below)
‍2. Create a brand (see below)3. Create a campaign (see below)‍Each step requires approval by our voice and messaging provider, Twilio.

Required Information

The required information below will be gathered and documented by Case Status in any way that will make it convenient for us to reference and input (e.g., copy-paste) into a web form. You do not have to compose formal documents for submission, but ALL information is required. Please review the examples provided.

1. BUSINESS PROFILE
Business Name

Physical Address (Street, City, State/Province/Region, Postal Code, Country)

Business Type (Sole Proprietorship/Partnership/Corporation /Co-Operative/LLC/Non-Profit)

Company Type (Private/Public)

Stock Ticker & Exchange (if Public)

Business Registration Number and Type (For A2P 10DLC registration, you must provide your Tax ID / EIN)

Industry

Website

Regions of Operations

Authorized Representative (Note: Authorized representatives must be publicly verifiable employees of your company: Last name, First name, Email, Title, Job position, Phone number)

‍2. BRAND
Company type (Private, Public, US Non-Profit, US Government)

Stock Ticker & Exchange (if Public)

3. CAMPAIGN
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A. Campaign Description

Provide an explanation of campaign objective or purpose.

If where and how the customer provides opt-in is unclear, the campaign will be rejected.

Examples

‍GOOD: This campaign sends messages to customers who have signed up using our website [link to website] requesting to receive additional information about our new product line. We use these messages to help determine customer availability to have a phone call.

‍POOR: This campaign sends messages to customers to help schedule phone calls to discuss our new product line.

B. Sample Messages

Two (2) sample messages are required.

Sample messages should reflect actual messages to be sent under the campaign.

Guidelines for composing sample messages:

(i) Do not use placeholder text for your sample messages.

(ii) Use brackets to indicate templated fields in the sample message.

(iii) Be consistent in sample message, use case, and campaign description.

(iv) Provide Opt-out when applicable.

C. Message content
‍Will messages contain the following information? (YES/NO)

(i) Embedded links

(ii) Phone numbers

D. How do end-users consent to receive messages?
‍Describe how and when consumers opt-in to the campaign, therefore giving consent to the sender to receive their messages.

The call-to-action must be explicitly clear and inform consumers of the nature of the program.If multiple opt-in methods can be used for the same, list them all. Be sure to: (1) Provide a website where opt-in occurs. (2) List all opt-in methods. (3) Ensure any provided website is be accessible, with a privacy policy and terms.

If where and how the customer provides opt-in is unclear, the campaign will be rejected.

Examples:

‍GOOD: Customers provide opt-in specifically when enrolling into our website or in person by requesting SMS capabilities within the store. Opt-in during website registration is a self-service process and occurs at acme.com/signup. By submitting, you authorize ACME to send text messages with offers and other information. Message/data rates apply. Consent is not a condition of purchase. [Link to terms and conditions]

‍POOR: Customers sign up.


SMS Opt-in Guidance
An example of an opt-in system could be a website where prospective customers sign up to receive messages. A comprehensive opt-in solution should contain the following:

- Program name and/or a description of the messages that will be sent

- Organization or individual being represented in the initial message

- Fee disclosure (e.g. "Message and data rates may apply")

- Service delivery frequency or recurring messages disclosure (e.g. "Message frequency varies")

- Customer care information contact information.

- Opt-out instructions (typically "Text STOP to cancel")

- Link to Privacy Policy describing how end-user opt-in information will be used

- Link to Terms and Conditions describing terms of service

‍- A checkbox option that end-users must select in order to receive SMS messaging. The checkbox can not be pre-selected. The checkbox provides the end-user the ability to agree, or not agree, to receive SMS messaging.

‍Please refer to the CTIA guidelines for detailed instructions and best practices on handling consumer consent. Please consult with your legal advisors as required on fulfilling the requirements as they apply to your use case and organization.

‍Additional Campaign Guidance
Additional guidance and best practices can be found in Twilio's A2P Campaign Approval Best Practices.

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‍Frequently Asked Questions
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‍Is it possible to get an exemption or extension of the timeline?
‍Unfortunately, no providers are able to extend the time frame any further, or grant exemptions; all registrations must be fully completed by July 5th to avoid the block on unregistered traffic.

‍Why is Case Status enforcing registration when another service is not?
‍These requirements are coming from wireless carriers (AT&T, T-Mobile, Verizon, etc) in order to reduce spam. Registration is required for all messages sent via A2P (application to person) system. Any other SMS application will also require A2P 10DLC registration

‍Am I required to obtain consent (opt-in) from a prospect before sending text messages?
‍Yes. Not only should you obtain consent, but you should also have a system in place that records their consent. An example of what a good opt-in system looks like can be found here.

‍There are other types of business registration numbers to choose from in the form. Can I use one of them instead of the EIN number?
‍EIN numbers are required for the A2P 10DLC registration process. Any other registration number will not be approved for this specific use case

‍Is there a way to automatically include opt-out language in texts sent through Case Status?
‍There is not. This will need to be included manually in any templates or texts sent. Please note that opt-out information should always be in every message.

‍What keywords are detected for opt-outs?
‍STOP, UNSUBSCRIBE, END, QUIT, HALT

‍Does this opt the prospect out in Case Status?
‍It does not. However, it does prevent texts from sending number to the prospect’s number. You will need to manually opt the prospect to prevent messages sent from other numbers.

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