[VoiceOps] VoIP SMS Campaign Fees

Mon Nov 29 17:37:01 EST 2021

I look at this like this:

If I threatened to charge $10k fees to t-mobile because they didn't use a website i told them to use, that requires individual due diligence and paperwork before sending my users text messages that were business related, they'd laugh at me vigorously. Even if I told them "no, it's ok, I just need you to do this for your business customers. Just remove texting from all your business users (and individuals using their phones for small businesses) and charge your business cell phone customers more, what's the issue? Don't forget to maintain all this other data on behalf of the random end users you deal with to ensure they stay in compliance with acceptable texting"

It's only OK to do to us because we're smaller than T-Mobile, and they can just block our customer's services. This would be insanely illegal to do with voice traffic, and would raise all sorts of competitive concerns.

But cartel behavior is somehow OK if it makes a laughable attempt at addressing spam texts.

I shouldn't need mom's permission to send texts. This is still a public switched phone network, right?

-Paul

________________________________
From: VoiceOps <voiceops-bounces at voiceops.org> on behalf of Peter Beckman <beckman at angryox.com>
Sent: Monday, November 29, 2021 4:52 PM
To: Carlos Alvarez
Cc: voiceops at voiceops.org
Subject: Re: [VoiceOps] VoIP SMS Campaign Fees

While I understand the concern, and it is warranted for your customers who
are using 10DLC numbers for business-related SMS, The Campaign Registry
(TCR) will evaluate your business case for P2P if you have a valid one,
such as a business that offers residential phone service.

I've implemented the CTIA Best Practices as best I can in code to block
customers who attempt to use our clearly-stated P2P SMS service for A2P
purposes. They get blocked immediately, we get notified, and we educate
them on the current SMS landscape and explain why they cannot use 10-digit
local US Numbers to send business SMS without registration. When we explain
the costs, they usually complain and go elsewhere.

I'll be curious how Twilio and Plivo and others are going to handle this. I
know that Twilio treats all SMS traffic as A2P from a fee perspective, but
with the whole registration business it's gonna get ugly quickly.

The Campaign Registry offers an API, so I'm assuming that 3rd parties will
tell customers to go register their brand and they'll enable SMS once TCR
approves. https://csp-api.campaignregistry.com/v1/restAPI

For any business who has legitimate P2P traffic -- see the CTIA Best
Practices -- contact TCR to see if they agree.

Beckman

On Mon, 29 Nov 2021, Carlos Alvarez wrote:

> Alarmist is warranted.  I am equally perplexed by the inconsistent rules,
> the vague language, and by everyone insisting that T-Mobile will
> unilaterally issue $10k fines per message.  On what authority?  What is the
> appeals process?  Dozens of questions, nearly no answers.
>
> I just sent a text from one of my business numbers in response to a client
> who texted it.  Is this a campaign?
>
> The whole thing where everything that's not another cell phone is
> considered automated and not P2P seems disgusting, if not actually illegal
> and fraudulent.
>
>
> On Tue, Nov 16, 2021 at 4:16 PM Oren Yehezkely <orenyny at gmail.com> wrote:
>
>> Nate,
>>
>> See a thread I started a few months ago about this matter.
>> I got a lot of negative responses for being an alarmist.
>>
>> Basically these requirements are set by the different mobile carriers and
>> they are not the same.
>>
>> Yes, they all consider customers to be businesses (A2P). No customer is a
>> consumer (P2P) in the eyes of these
>> carriers, TCR and even the person who answered you before.
>>
>> I don't think that the penalty is $10,000 but VI may be trying to deter
>> you from using SMS
>> without registering. You may want to consider using a different carrier
>> for SMS.
>> Other carriers will also offer to help you register with TCR.
>>
>> Good luck with dealing with that headache, feel free to contact me off
>> list to see if we can share some information
>> on dealing with this.
>>
>> Regards,
>> Oren
>>
>> On Mon, Nov 15, 2021 at 3:37 PM Nate Burke <nate at blastcomm.com> wrote:
>>
>>> Sorry if this was already discussed and I missed it.  I saw a notice on
>>> our Voip Innovations account today that any business DID's that send SMS
>>> messages to a consumer in any way now have to be registered with
>>> 'Campaignregistry.com'  Looks like this requires a $200 signup, and then
>>> potentially $10/month/DID.  Anyone already gone through this?  Talking
>>> to VI, it seems they're not even sure, but it's a VI requirement to be
>>> registered by Dec 15.
>>>
>>> The whole process seems confusing.  VI Makes it seem like non-compliance
>>> will be expensive. $10,000/violation keeps being referenced.
>>>
>>> Would each one of my customers be considered a separate campaign at
>>> $10/month?
>>> _______________________________________________
>>> VoiceOps mailing list
>>> VoiceOps at voiceops.org
>>> https://puck.nether.net/mailman/listinfo/voiceops
>>>
>> _______________________________________________
>> VoiceOps mailing list
>> VoiceOps at voiceops.org
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>>
>

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Peter Beckman                                                  Internet Guy
beckman at angryox.com                                https://www.angryox.com/
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