Following the Rules of the Texting Road -Fireside Chat with Author of CTIA Guidelines

All right, Michael, let’s get started here. sounds great. So thanks everyone for joining us. Today is Wednesday, October 25th. And we’re here as the second session in the True Dialogue Learning series tonight’s today’s topic, following the rules of the road of the texting road fireside chat with the author of CTIA guidelines. As people are joining, I will do a brief. speaker introduction and then we will drive right in. John Wright has served as CEO of TrueDialogue since 2014. Prior to his role at TrueDialogue, John held senior leadership positions with Flow Network, acquired by DoubleClick and DoubleClick, which was acquired by Google for Tiva, acquired by Proofpoint, Digital Impact acquired by Axiom. John is considered a subject matter expert in online and offline data, database marketing and marketing automation and high growth management. having spent much of his career connecting online and offline audiences with retailers through ad tech, e-commerce and CRM platforms. And John is based in Austin, Texas. Brian Jones Lancy is head of compliance spam and fraud mitigation at Cinch. He is a thought leader with over 20 years of experience in the operational and executive management of telecommunications, technologies and services. With practical experience in network planning network operations management and telecommunications policy development Brian has functioned as a consulting telecommunications specialist with industry organizations such as G F M A M M A I T W C A N T O F C C vendor group and CTIA he has conducted consultancies for several members of Congress as they develop legislation around the emerging tech technologies such as RCS MMS. SMS and TCPA. Of his three master’s degrees, Brian holds a master’s of wireless telecommunications from Edenborough University in Pennsylvania and is presently pursuing a doctoral degree from Johns Hopkins University. He’s fellow of Telecommunications Engineering and Management Institute of Canada and also a guest lecturer at the University of Maryland and the United States Naval Academy. He resides in Annapolis, Maryland, fiercely loyal to the benefits of that area. And if you don’t, if you have any doubt, just ask them. John, I’ll turn it over to you. Great. Well, I want to thank everyone today for joining. And for those of you who have other team members that would like to get a view of this, this is being recorded and will be published on our website. Per the discussion point here, I do want to just point out that we are very fortunate to have Brian join us today. He is the one of the original contributors and author of the CTIA handbook, which those of you who are customers of True Dialogue, we go over that during your onboarding process. And today we have constantly have barrage of questions into our client services team with regards to best practices. And this is an ongoing effort inside of our organization to make sure that our clients and prospective clients are up to date on the all things short code, long code, phone calls, et cetera. And Brian is, I would say as witnessed by his bio, probably not a subject matter expert, but the subject matter expert when it comes to this. And we’re just very fortunate. Brian, I want to thank you for joining today and we will go ahead and get started with our presentation. And I’m gonna let you… start here and we’re going to kind of go over several kind of critical pieces of information here. But at the end, there will be a Q &A. You can submit your questions online. And again, Michael and our team in the marketing department will be putting this on our website and distributing access links to this video for later reference. So thank you. Yeah, John, thanks so much. Really do appreciate it. I wanna talk to the attendees here. First off, I was part of the group that helped to create the CTA guidelines. I was part of the author team that worked with the Mobile Marketing Association and actually helped to build that as the mobile messaging guidelines document, the importance of this as a platform solution is really that, we understand that the rules of the rule the regulations. down from the FCC, then it comes down to things such as TCPA, then it comes down to the carriers, and it comes down to what is the best practices to assure that the consumer has the best experience through the market itself. And the way that you can assure that the consumer has the best experience is that look out for the path that the consumer one signs up for your campaigns and how you’re actually getting a hold of them. Two, make sure that they understand that they can text help for help at any time, to stop the campaign at any time. And also make sure that the communication outbound to the consumer, the subscriber, always reminds them of whom it’s coming from. Day in, day out, consumers had hundreds of text messages. And when text messaging first came out, or mobile messaging first came out, It was very personal. was a message from my brother to me, my sister to me. So I, as a consumer, I interacted with it right away. And now businesses have access to text messaging or mobile messaging to me as a subscriber. So you have to make sure that that message out to the subscriber from a business is very, very personal. It’s very relevant and it’s very timely to the subscriber themselves. If you miss the mark on any of those things, personal, relevant, and timely, you are absolutely going to make sure that there’s going to be a fault or a failure. The slide that we’re showing here talks about a company such as TrueDialog or company I work with today, Cinch, that you can specifically assure that one, the message that you send out should and does go to the right individuals. Two, that it’s not being spoofed, that there is proper content, there’s also proper content that goes through. And then three, making sure that you stay away from the areas of shaft except for in the areas of AFT, which is alcohol, firearms, and tobacco. We’ll talk about that in second. The first bullet point is make sure that you understand If there is a violation, what’s the escalation process? Does it go to the MNO first? Does it go to your messaging provider? How exactly is that resolved? Because you want to have a path right at the very beginning, okay, I’m gonna work with Cinch or Twilio or Bandwidth, and they’re gonna be my aggregation partner. What happens when there’s an outage or there’s a violation? And make sure you talk about that ahead of time. Also, make sure that you’re working with someone that has their own internal filtering tools. internal filtering tool can be like what we have at Cinch, the ambient tool. Or it can be such as a tool that’s external, like Proof has one or CloudMark. And there’s a multitude of different outbound third party solutions that you can. specifically work with are compliant and are specific to how they show. One of the things that we’re seeing a lot of challenges with this year, right now, this quarter is URL filtering and phishing, as well as making sure that you’ve got a very, very specific and very, very precise vetting of those different types of URL filters and uh, URL, uh, uh, solutions that look at fishing and fraud and things of that nature. And the last piece on the left-hand side, some of the safeguards you want look for are things such as, um, automated filtering on shaft. uh, sexual, uh, traffic, hate, alcohol, firearms, and tobacco. For alcohol, firearms, and tobacco, you absolutely have to have age gating on the message itself. The very first message that goes out, you have to have it. different areas such as gambling can be no bueno, it can be bad on certain carriers. And then there’s always disallowed content. In the United States, we are not allowed to send out messaging, which is the promotion of, marketing of, or distribution of or sale of cannabis. And that’s obviously a big concern for the larger group. So it’s definitely something that we want to take a look at. We want to make sure that we’re… we’re vetting for and we’re making sure that we’re keeping as compliant as possible. John, I went through a lot there, so I’ll see if there’s any questions. Let’s see here. We already got some stuff that’s kind of popping in the queueing. And the first question comes in and says, with carriers blocking SMS as A2P 10 DLC came to the forefront, we have seen this happen to volume that you have access to see. Was there a big drop in outbound A2P? mark. How much of it came back as companies have become compliant? I’m assuming he’s talking about that’s a really good question. Yeah, yeah. So, so what happened is that. On codes has existed as a channel for quite some. Brian, Can you hear me? Yes, I’m not sure if you’re the I’m the only one, but it seems as if your audio is kind of going in and out. Did Michael were you hearing having audio issues with him as well? Yes, I was. It’s better now. Okay. All right. Specific to these questions with Tenge’s long code, Tenge’s long code registration was required several years ago and it was required to go through a company called TCR or the campaign registry. As that happened, A2P messaging spiked because small, medium businesses saw ways. The carriers were assured that this would be a channel that would have very clear, concise messaging and it would not be in any way spammy or have any sort of scams across it. That in itself, it was a problem because there’s always bad actors that are out there and that are able to find different ways that they can really send spoof traffic that they can send illegal traffic through this. As a new channel, 10-digit long code has come about, it’s been very evident that this is one of those areas in which there’s gonna be problems. We’re working very closely to assure that the compliance aspects are being met, that they’re being adhered to, but it is definitely an area of concern and effect. So definitely good questions there, John. Yeah, I’d like to just kind of take one thing in and layer it in a little bit on top of that, Brian, which is that at TrueDialog and ProlTransparency, Cinch is one of our aggregators and we’ve been working very closely with them since I came on board. And they are very trusted with regards to being one of the tier one providers. What we’ve seen at TrueDialog is inconsistency with regards to deliverability on 10 DLC. And I think that that’s just really more a end all as far as the carriers are trying to get better at figuring out what traffic is allowable as they’re putting in better filtering tools, identifying and missing false positives. We still see that if you have things like emergency alerts, Transactional messaging, fraud alerts for our banking clients, very important messaging with high volumes attached to it. A lot of universities that we work with have this, that short code still has less filters applied to it and much higher deliverability. And I think that’s also part and parcel to 10 DLC registration can happen in a matter of five days. Short code onboarding and vetting. with our with Cinch even can take between eight and 12 weeks. So it is a, they go through a lot more scrutiny. They also go through a lot more monitoring with regards to ongoing monitoring of short code traffic. I think that 10 DLC is subject to a lot more filtering. That is what I would call AI based versus short code which does have some. filtering that’s applied to it, but not near at the level that 10 DLC is. And I’ll kind of leave it at that. Mike, I’m not sure if that is accurate, but that’s what we see on our end, Brian. Yeah, and I think that that’s accurate. mean, the amount of filtering that is being done is there is definitely some that’s being completed through AI solutions. There’s also some that’s being completed through just randomizers. that look at volume metrics. There’s also some that’s creating a lot of what we call in the industry false positives. messages should be flowing through, but they’re getting blocked. They have to be reviewed and it can be problematic and concerning. The timeframe to go to market is definitely because there’s been a greater amount of scrutiny on what is called KYC, Know Your Customer, as well as vetting, where we’re required to have a much more stringent vetting protocol on all of the messages that go out from our platform and everyone else’s platform. Now, there’s been a lot of discussion and what we’re showing here are guidance documents for regulations as well as guidance. to and allow for different types of messaging to flow through. The fourth one down, which is the TCPA, which is Telephone Consumer Protection Act, was created through and by a division of the federal government. And that specifically was meant to talk about outbound communications, calls, phone calls. And they put a little tiny piece in there. later as an amendment to talk about the mobile messaging. Now, the other documents that you see, CTIA, political messaging, T-Mobile Messaging Handbook, AT &T SMS, Intentional On-Go Guidelines, those are documents for which the carriers require different components to stand. So the carriers are requiring things such as help messages, proper call to actions, proper opt-ins and proper opt-outs. as campaigns are sent in to for Tengent, Long Code or SMS, there can be some delays in regards to how those messages are reviewed and how they’re vetted and how they’re approved. So, if you’re seeing a long lag time with your aggregator, definitely go back to them and say, is there something that we’re doing? Are we missing something in say, CTIA best practices document? Are we missing something in say, the… AT &T document or any of the other carriers documents, because those will absolutely affect how fast your campaigns can be approved. Great. So you want to move on to the next one or do you want to spend a second on the guidance documentation, Brian? No, mean, the guidance documentations, these are hot links. We will send this out at the end of this webinar. But these are all You know, public documents, they’re updated typically on an annual basis. Um, and you can go to these sites to take a look at them. Um, the, uh, there’s, there’s legislation now to talk about robo calling a robo protection. Um, and that’s really for voice, but the TCPA is, um, what is considered kind of like the Bible of actual ledges, hard legislation. where the other ones can be considered as guidance from the carriers. But if you vary from them too far, it’s really, you’re going to get yourself in a lot of trouble with the carriers. You even could get your campaign shut down. Great, so we do have some political customers. So I think it’s important to spend one of the top link here with regards to as we’re heading into that season, let’s talk a little bit about political campaigns, Brian. Sure thing, yeah. So political campaigns, very much it’s going to get on the tip of everyone’s tongue. Q4 is gonna be a heavy ramp time for political messaging, we know this. Q1 of 2024, very, very busy and Q2 is just going to explode with the amount of messaging that’s happening out there. The important thing is that we’re going to see a considerable amount of examination of the type of messages that go out. Some of the areas that I’ve put in yellow here, which are unacceptable political guidance areas are and can be things such as libelous, defamatory, you know, that contain hate speech, violent or racist rhetoric or material that’s expected to be offensive to the published user. Now, I want to be very clear. This is a guidance that I’m stating here. It’s very difficult to take a look at something and say, Hmm. Is that deflamatory language? But maybe not because if it’s, if it’s something that is against one candidate, could I say it’s against another candidate and, and will the carriers, you know, hold me to this an area in which political messaging can, and I have seen in the past, get into problems or where they contain hate or violence or a racist rhetoric. And those, those areas right there. are really where you want to stay away from. Anything like in the hate speech or violent speech or racist rhetoric, that is absolutely gonna get flagged. One of the components that we’re seeing right now is that the carriers are able to come back to direct carrier aggregators such as Cinch, and they’re able to ask for specifically opt-in audits. What is an opt-in audit might ask? An opt-in audit is where the carriers say, hey, my cousin got a message from the Biden administration, but he doesn’t think he ever signed up for that. You, Cinch, you have to take my cousin’s number. You have to go back to your political sender and you have to prove to me that my cousin actually signed up. And I’ll be honest with you, it’s a challenging. It’s a challenging exercise because you have to go all the way back to how did that cousin sign up? What was the specific way that they signed up? Was it written consent on a little card? Did they go to a website? Was it verbal? And then they clicked on that. So that’s a big area that the carriers are looking at this. The carriers also look at opt out volumes. So if a volume of the messages that are being sent out, there’s a super high amount of opt outs and it’s different for each carrier, what that threshold is. Then they themselves can come back to us and say, Hey, look, you have to examine this. We need to see what, was the intent or what was the originating message that went out? What was the intent of it? Who was the intended audience? Did it go to the wrong audience? Why is there such a high opt out rate? And That’s one in which it takes quite a bit to take a look at what was the message there. So political messaging, definitely, we’re gonna see a ton more of that coming through. Make sure that you’ve got proper opt-in before you send the messages out to the subscribers or the consumers. Make sure that you stay away from messages that contain hate speech, violent speech, racist or rhetoric speech. And also make sure that if you’re a political sender entity that you go to CampaignVerify and you get your political entity registered through them because that’s a really good way to assure that your organization is allowed to send out political messaging. On 10 Digital Encode campaign channel, you actually have to have a validation key of K, the letter K, before you can actually click the box saying that you’re political messaging. One of the other components that we talked about here was how can we assure that the messages that you send out are clean and clear? And some of those areas are looking at the do not call registry. So taking your database and comparing it against the FTC’s do not call database, you can pull down the database on an X number of basis and you can look to see that you’re scrubbing against the DNC list. How often should you do that? I would say depending upon what’s the volume of sends that you’re gonna send out there, maybe once a week, maybe twice a week, you should really have an API setup so that’s an automated system. The next one that we wanna talk about is fairly new, it’s about two years old. It’s the reassigned number database and it went live in November of 2022. Um, it’s, it is, um, you know, a new component, a reassigned numbers are where a number was on AT &T. Then it moves over to T-Mobile or John had a number. Then he said, I don’t want that number anymore. And then it, it sits in like a queue for up to 90 days, and then it can be reassigned. Well, John. maybe he had signed up for all these other different campaigns and messages, know, um, weather app or cooking show app, or, you know, he likes race cars. So, you know, he’d get, you know, updates on that when that number gets reassigned, all of that communication has to stop. And so the, the R and D has the record of those, those numbers that are in that database and the brands should be scrubbing against those numbers. Let’s go to the next one, And then carrier deactivation files. Carrier deactivation files are where and when a carrier has a subscriber and they deactivate the number. Perfect example of this is a friend of mine moved from the United States to Germany. Well, they don’t need their USA number anymore. So they deactivated it. Well, the carriers have what’s called a deact file. That DACT file is shared on a weekly basis or a daily basis, depending on the feed, back to the DCAs, the aggregators, and the aggregators can share that out as needed. This is really, really important because the carriers, this is something that the carriers can control, like the RND and the DNC, that’s controlled by a private company and the government. this is controlled by the carriers and the carriers really want you to not send messages out to numbers that are deactivated. So if you do, that’s a really big thing. Yeah. just want to say one thing. We’ve worked very closely with Cinch and every one of our clients behind the background, you don’t need to do anything. This is automatically being applied to your file. And this is again, one of the things that TrueDialog does. for all 3000 of our clients basically specifying and ensuring that you guys are in compliance with what the carriers, this is again, and I think the other thing that’s important to this that we’ve seen is that this only doesn’t do deactivations. So as Brian was talking about, he goes to Europe, he deactivates his phone. He doesn’t give his phone number up, but he comes back in and then he’s reactivated. there’s a reactivation component of that file as well. So when that phone is reactivated, it will reactivate that number again in your database. I think further to that point and probably more common in some of our clients that have, I would say users, younger students, people that might have payment issues. That also includes people who don’t pay their bill. Their phone is deactivated while their bill is being paid. And then when that bill is paid, it is then reactivated. This does two things. Number one, it keeps you in the good graces of the clients. But number two, you have to remember SMS is a technology that was developed in the late seventies and early eighties. What that means is that the technology itself and the infrastructure is still limited in some capacity. When you’re sending out large volumes of traffic to numbers that are not active inside the carriers, it’s hard for them to manage it sometimes. This is a breathing point for them. and as best practice and is offered at no charge and automatic as part of every one of our customers has access to. Thank you. Yeah. mean, that’s, that’s awesome, John. And that’s exactly what you should be doing. You want to have like a really, really good, um, scrubbing. And that’s what this last one is. Um, make sure that the, you are also tracking and I know that your dialogue does this as well, but make sure you’re tracking the opt outs. There are five keywords that a consumer can use, can use to opt out of a campaign. And those keywords are critical for. your aggregator, your partner to listen for and to then make sure that they opt you out. This will assure that I, as a subscriber, I don’t get messages that I chose not to. The biggest way that you can get into a financial situation with fines is that if I choose to opt out, I send you the proper keyword. One of those keywords is stop. If I send you stop and then you continue to send me messages after that, not just the confirmation word, the confirmation message, but if you continue to send me messages beyond that, that’s when you can get in trouble and you can get fined up to $1,500 per message that gets sent out. So this is where it can really, really escalate and get way out of hand. I think there’s two things that I just want to be clear on here to some of our customers. Number one, we also have additional practices that we go through for additional opt-out scrubbing. We have additional filters on our inbound message handlers that look for excessive profanity, things that are obvious. People do not want you on their list. We’ve also created kind of certain other lookups that we know are obvious and consistent with regards to people that do not want to be on the list. we go through some additional steps, but I think it’s also just a good practice to take, go inside of your true dialogue UI, filter on looking at inbound messages and just constantly kind of doing an audit of your inbound messages to make sure that there might be something that is consistent that will stop. And for our customers, we also have all of those in French. There are other languages that are consistent because if you’re on a French short code, all of those are required by the… Canadian aggregators. And last but not least, one of the other things that I think is important is that there is one exception to being able to message your users. And we have some universities and colleges who constantly ask, well, if a student has opted out of receiving information about their next term’s coursework, how do we alert them that there is an emergency on campus? There is one exception and one exception only to messaging and being able to message beyond and off doubt. And that is an emergency alert. And the carrier’s designation with regards to that is that, and thought process on that from my experience, and Brian has a heck of a lot more of it than I do, is that they will make exceptions in that case, but that needs to be very specific. and you have to keep a separate subscription that is for emergency alerts, which our system will allow you to do. But again, we have clients who use our systems in a variety of ways. Best practice is always to take them off. But if you do have that concern, again, stated specifically inside of TCPA, emergency alerts are void of that particular opt-out requirement and being able to message beyond that, but only emergencies. Yeah, you’re exactly right, John. And the best practice for that is really to have a separate code for those emergency alerts. So you bring up a good example. My daughter is in college right now and she gets alerts all the time about this or that at campus. But she, like you said, she can choose to opt in or opt out of those. But the emergency alerts one, she, you know. She cannot, but the campus must be very prescriptive of how they use that. They can’t send it out of, hey, there’s sweatshirts available in the gift shop. You know, this is, this is like active shooter on campus type of thing. And those, every single one of those messages that goes out is scrutinized by the FCC. So they have to be careful about what they send out. And I think like another example, we’ve got several professional sports franchises. If you’re in an outdoor stadium and there is a lightning concern, obviously that would fall underneath the same designation and because people are in harm’s way and the idea is to get them out of harm’s way. So that’s kind of the way I justify it in my brain. You know, is a pipe breaking in the student housing facility a real emergency? We call that maybe an urgent alert, but it falls outside of what I would call a critical alert that would not be subject to traditional review by the carrier. So with that, We are now at a Q &A session. We’ve got another question that came in, and I think this goes back to 10DLC and volume, Brian. And as far as, you seen a change in volume with regards to non-compliant volume getting blocked since the carriers have implemented and start making additional charges on non-compliant, meaning people that are on 10DLC and haven’t registered? I think there’s an important designation in that number one, non-compliant and non-registered are two separate things. Non-compliant in my book, and I’ll let Brian answer shortly, is that non-compliant means that maybe it’s one of your marketing cannabis, which is one of the things that the carriers do not want to happen on their networks. Non-registered is the other thing, which means that You’ve not registered your 10 DLC circuit. The carriers will continue to accept it as long as it’s not in one of those non, one of the categories that they don’t want messaging on, but you will pay a higher rate. Brian, I’m gonna hand this over to you because you probably- No, John, you nailed it. You absolutely nailed it. So non-compliant is exactly what you said it is, content that shouldn’t go through the network itself. Unregistered, however, is different from registered and- The carriers are now starting to put the screws down a little bit on unregistered traffic. Your partner, TrueDialogue, Cinch, we are starting to get that communication from the carriers and are sending out CNs or client notifications about the different registration deadlines. I know that there’s a deadline coming up in November. I know that there have been previous deadlines that were stated and then pushed out. the carriers are still trying to work through these deadlines, unregistered traffic and how they can handle it and they can work through it. But yeah, the carriers are really looking at unregistered traffic and what are they gonna do with it moving forward? They see it as a problem. I don’t see it as that much of a problem, but I think that we should be cognizant that the carriers want all the traffic to be registered. If it’s not registered, you’re right. It goes to a much higher throughput costs. think the important thing on top of this as well is that not only are they looking at it, I think this is another important move that you mentioned earlier, which is the carriers are forcing companies like TrueDialog, who are providing services to our end users, as well as aggregators like Cinch, who TrueDialog uses. Bandwidth is another aggregator that we use, but Cinch is by far our largest aggregator. But I think what the carriers are saying is that you much like banking and everything else with the proliferation of fraud that has continually happened over their networks, they are shutting it down. And that is in phone calls, that is in text. And the reason why you’ve got to register your traffic. So if there is a message that goes out on one of the numbers that’s associated with your campaign registry campaign, they know to go who to go talk to. And my experience today is that It is quite an effort if you registered and you’ve sent out something that is not in guidelines with what you’ve registered your traffic to be. So for instance, say you’re doing, I’m doing a two factor authentications using 10 DLC. And all of a sudden you start sending marketing messages over that 10 DLC circuit. They’re gonna flag that number. They are gonna shut it down and they are gonna review it. And it takes, you’re not talking about a seven day uptime to get that reviewed. It is going to take. four plus weeks in order to go through the ecosystem because there are that many more 10 DLC circuits that are on the market than a short code. The remediation process on short codes is much shorter, but also the carriers, they have less filtering that goes on there and they also have less tolerance on site of short codes as well. any other questions that we have today? Hopefully that got Jacob’s questions answered. Anybody else have anything to say? Got one more chat question here. Okay. John, John, can, I can read two quick ones that I see if that’s all right. Uh, being mindful of our time. Uh, can, can you, can you walk through best practice to ensure consent for a texting program? Uh, yeah, absolutely. So John, let’s, let’s, uh, let’s tag team this one. So, um, consent for any sort of texting or a mobile messaging platform simply means that the subscriber has the opportunity to give. either express or express written consent and implied consent is always in the gray zone. So we prefer that they have express or express written consent to the campaign. A very basic one is, so I live in Annapolis, Maryland. We’re having the fall brawl this weekend and it’s a Viper sailboat race out on the Chesapeake Bay. It’s gonna be a beautiful day. But after that, we’re going to go to the yacht club and we’re going to have some adult beverages and there’s going to be a sweepstakes to be given away and other things that you can buy on your phone. But to get that, you have to download a short code and there it’s just going to be a quick call to action keyword. And that keyword is just simply going to be join. And then what you would do is you would specifically just text in the word join. And then you would get a message back or a call to action message says, dear Brian, you’ve chosen to sign up for the fall brawl sweepstakes. If this is correct, text in yes, or if not, text in stop. And if a consumer texts in yes, then they are part of the sweepstakes and they can receive the communications. That’s express written consent. However, if a consumer does not, respond, it is not presumed that they want the messaging. Okay. Just because they said, join, sometimes they have to do what’s called a double opt in. And if they don’t do it, you can’t send a messaging. So if you’ve got a double opt in component there, you have to be very, very careful. Um, John, maybe you have an example of what, what, know, of a proper consent for people joining in. I, I, I’m going to kind of go off a. just a little bit here, but I think one of the important things that we’ve kind of encouraged our clients along to do is that, and this has been a traditional practice in the direct mail and even email world, which is get 10 % off for joining our list, text in, subscribe. One of the things that the carriers, and I think this has been an effort and being one of the original people in the email industry is that the carriers have said, we own ISPs, we are not gonna let our carrier networks What happened inside of email happened inside of our carrier networks. And one of the things that’s very specific inside of the CTI guidelines is that when people opt in, you cannot have an incentivized opt in, meaning that you can’t give them 10 % off in order to join your list. It has to be unincentivized. And I think that a lot of people look at trying to, how to increase this subscriptions inside of their list through incentivizations. And they’ve asked us and they’ll ask in a variety of ways. And I think the standardized answer to this is you cannot have an opt-in program that is incentivized. And I think that’s important to note. And Brian, I’d love you to hear your thoughts on it because a lot of people try to do it, but it’s very clear with regards to the handbook, what you can and cannot do. Yeah, and that’s the thing. And let’s talk about that a little bit, John, because we get that question all the time. Like, can I give discounts? And you absolutely can. but you cannot give discounts to sign up. You can give a discount once someone has signed up. Oh, you would like to be part of our Under Armour program, which is also based in Baltimore, which is just north of here in Annapolis. But do you want to be part of the Under Armour family? Yes, I do. Text JOIN, I JOIN, and then I confirm that I want to be part of it. And they say, Hey, Brian, thanks so much for joining. Can you give us your birthday month? And I give my birthday month, they’re like, oh my gosh, October’s your birthday month? We’re gonna send you a 10 % discount for this. That type of communication is compliant. But if you simply say, text to this and we’ll give you a 10 % off, that always gets people into trouble. And it’s just an area in which the carriers, they look for that because what that does is it’s considered kind of a Not kind of, it’s definitely considered a bait and switch type of a thing. Information should not give you a discount. Usually doesn’t always work. The codes are oftentimes off. it’s just, it’s a bad practice. Great. Well, I think is there any more questions? I can’t see any, Yeah, we do have one more and that’ll bring us to the end of our time. What are the level of violations that a carrier has and how do they respond to each? That’s a great question. The level of violations. Yeah, Brian is the one that’s closest to that. So the level of violations in the United States for the United States carriers are this and stop. You have a severity zero, severity zero level, is things such as disallowed content, adult solicitation, pornography, human trafficking, violations of shaft. Those are. things that would qualify for SEV 0. Then you have SEV 1 or SEV 2. SEV 1 is you have issued policy policy, my terms, or it’s just completely wrong. That will get you flagged by a SEV SEV one or SEV two. Now in Canada, very relevant to this market. It’s they have just it’s SEV one, two and three, but it’s the same thing. It’s just they’ve just bumped it up a little bit. And the infractions in Canada very much mimic the United States and the United States mimics and these carriers talk to each other. So you have to be very, very careful about the type of messaging that you send out because yeah, you get an infraction of a SEV zero. The carriers can, not saying they can share it between each other. And so if I get a SEV zero on say like AT &T, T-Mobile might contact me and say, hey, are you sending out cancer? And they could look at the message going through their network, oftentimes when there’s a sub-zero on one carrier, all of them are gonna flag And Brian, I can only speak from what we’ve seen as far as what the carriers will do with regards to these infractions is that sub-zero, that is number one, immediate. your code is turned off. I think that if the lower the number on the infraction, they can do things like suspend your code, or they can basically say, we are going to, you you’ve changed your terms and conditions, and they’re no longer in compliant with your shortcode application. Please update them. You have 10 days in order to get this done, or we will shut your code down. So, but in the end, It can be a blocking of the code. It can be a blocking of the code by one particular carrier. Because the other thing that we see is that every carrier acts a little bit differently and is a little more sensitive about some things. When it’s sub zero, they all act the same. They want it shut down. And the ultimate recourse of that is that they will terminate your code and there will be no chance in the future or in the near future of you ever being able to procure. a code underneath that EIN again. And that includes 10 DLC as well as, because the linking component of this is the EIN that you register with for short code and long code. It all goes into their database. And if you get hammered, they are going to put you on a watch list. You may still be able to use your business phones for communications on voice, but if it’s a texting infraction, they will likely limit you and you’re going to have to make special appeals. for to get either of those turned back on. And again, that goes back to the KYC, know your customer. That is the reason for registration is that unfortunately all of our clients act very well and do they make mistakes? Yes, we’ve had clients who their webmaster will go in and update something on their registration form and wipe out something that’s specific saying that T-Mobile requires in your opt-in language on your on your keyword opt-in form because they don’t know that it’s pertinent to their application. And they’re lenient towards that. They realize mistakes happen, but on certain things, there is no play. And ultimately they will get you shut down. And the biggest thing that I look at it as the carriers is that every carrier, costs them $60 every time a consumer calls up T-Mobile, AT &T and Verizon and makes a complaint. They want this traffic, they just want compliant traffic and they don’t want the problem phone ringing. And if you think about it like that, I think that you’re gonna have very good luck. And you would take a lot of the principles that Brian has discussed today, that how the carriers view things, the CTIA views things and how the FTC with regards to the TCPA, FCC reviews things with regards to the TCPA, I think you’re gonna be very successful because… I just got off the phone with one of our education clients. They have discontinued all email because it has become so degraded as a communication mechanism. Their CIO specifically stated, it’s a great way to talk to parents, it’s a horrible way to talk to students. And they’ve moved their entire communication strategy to their existing student pool to text. And the reason being, it’s very effective. I think the biggest thing you can do to make it ineffective, not only for yourselves, but as an industry as a whole is, to operate in the gray areas and there’s just no need to do it. So thank you for your time today. Again, as follow-up, this meeting ID will be published. And if you have questions, you can email either myself, which my email is jw at truedialogue.com or support at truedialogue.com. And if need be, we’re also happy to. submit further questions to Brian for you. He’s a busy guy, so we’re gonna take it easy on his email inbox today, but we’re happy to connect you offline if you’ve got additional questions that he might be able to help you with. And we thank you for your time. Have a terrific day. Thank you again, Brian. We really appreciate it.