Toll-Free Messaging Verification

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Toll-Free Messaging Verification

In an effort to reduce spam and tackle fraud, mobile carriers require businesses that send SMS messages to register their Toll-Free Numbers (TFN’s). TFNs that are verified are tagged as Verified and this tag accompanies the message along its way to the recipient.  Messaging traffic that does not have an accompanying Verified tag will not be delivered.

Verification does not guarantee that the business won’t experience any blocking.  Their message content and practices must be aligned with industry guidelines, and they must message within the use case that they defined during their verification process.  Mobile carriers are using AI to help filter Severity Zero (Sev-0) content like SHAFT-C, high risk financial services, get-rich-quick schemes, etc. that are prohibited in business messaging.  Businesses are expected to message their end users within the operating guidelines of their business.

To avoid message blocking, you will need to submit each of your customers’ toll free numbers for registration. Once your numbers are registered, the business TFN and use case will be approved for messaging to the US and Canada.

Spreadsheet Submission

No API has been available for submitting Toll Free Verification requests; however, we are beginning to hear news that this is under development.  The messaging aggregator intends to continue with manual registration for the time being.  Consequently, our Support Team is handling all submissions manually.

Just One TFN — No Snowshoeing Allowed

You may submit one toll free number per business location per use case.

One business sending outbound messages over a pool of toll free numbers is called Snowshoeing–a common technique used by spammers. Similar to the way a snowshoe spreads your weight across the snow, they spread similar messages across multiple numbers to avoid per number rate and volume limits, or to avoid raising attention to themselves.  Another example is a service provider who wishes to manage all compliance for their end users, rather than individually verifying (or getting TCR campaigns) for them individually.  This is no longer allowed in the industry. Each business who wishes to message their customers must follow compliance requirements and is directly responsible for their messaging content and practices.

We know that our customers’ end users use multiple TFNs for legitimate purposes.  However, the industry is trying to educate businesses and encourage them to consolidate their messaging to one outbound number in order to crack down on spammers. This actually provides a better user experience for your business and your customers. When you send messages consistently from one outbound number, customers can create a contact in their device for your business and know when you are texting or calling. They are more likely to answer the call or respond to the text, improving communication between your business and your customer or prospect.

What if my customer legitimately uses several Toll Free Numbers to message their end users?

The following are legitimate reasons for a business to operate with several TFNs:

Unique Use Cases:  If your business has a unique use case for each of your TFNs, you can submit each one for verification under its use case.

  • For example, they may have a unique TFN for marketing prospects, one for appointment reminders for current customers, and another for inter-office employee communications.
  • The business would individually verify each toll free number under its unique use case.

Separate Office Locations:  Each of your business locations can verify their TFNs individually, and the messaging industry expects this.  It is discouraged for a regional or national organization to message under one phone number when there are office locations that could better service their local customers.  This policy will vary based on the business’ vertical industry.

  • The office location must have unique information. It cannot use any of the same home office registration information, like address, contacts, etc.
  • The office location will have one sending number per use case.
  • Shared numbers (numbers used by multiple businesses) are disallowed and ineligible for verification.

Are there any fees to register my toll-free numbers?

We charge an admin fee to register your toll free numbers.  Because toll free verification is a manual process, our staff will submit your toll free verification, monitor the submission, and will assist you with any rejections or changes needed. Please contact our Support Team for more information about this fee.

Verification Class of Service

The toll-free aggregator now has two Classes of Service to classify verification status: Verified and Restricted.  Pending Verified was removed in January 2024 when they required all TFNs to be verified so that their outbound messaging traffic was not blocked.

  • Verified: Verified numbers have gone through the toll-free verification process and were approved. Their traffic is subjected to limited filters. If traffic does trigger any filters that specific content will be blocked but the number will not be automatically blocked.
  • Restricted (or Unverified): Restricted numbers have either 1) not submitted a verification request or 2) have had their application denied. All messaging traffic from Restricted (or unverified) toll-free numbers (TFNs) is automatically blocked.  Messages can always be sent out; however the messaging aggregator or mobile carriers will not deliver them to the messaging recipient when a Verified tag is not present. Consistent outbound traffic from unverified TFNs is strictly monitored and filtered, and treated as highly suspect.  To avoid having blocks placed on your TFN that are very difficult to remove, it is important to go through the Verification process and begin messaging upon receiving approval.

How do I submit my TFNs for verification?

To register your Voice Elements/Inventive Labs toll free numbers, please contact our Support Team.

Pre-Requisites for a Successful Toll Free Verification

Your business website will be reviewed by the messaging aggregator.  They are looking for any method where you gather a mobile number to make sure you get consent (like on a Contact Us or Text Us webform), and to make sure you state in your privacy policy how you protect the mobile information that you gather.

Webform:  On your website, if you have a required phone number field on a contact form, you must also include a consent statement with a checkbox.  The person must check the box in order to submit the webform.  This gives you ‘express consent’, allowing you to send messages as needed.  Here is an example of appropriate consent language:

□ I consent to receive text messages and voice calls. Frequency may vary. Mobile message and data rates from your cell phone carrier may apply. I understand I can opt-out at any time by texting Stop.

Privacy Policy:

  1. Your website must have an easy-to-find link to your Privacy Policy.  Most websites have a link at the bottom of the page.
  2. Your policy must explain how you protect the mobile information that you collect.  Here is an example of the language they are looking for:

By providing your wireless phone number to [insert your company name], you agree and acknowledge that [insert your company name] may send text messages to your wireless phone number. Message and data rates may apply. Message frequency may vary. You may opt-out at any time by replying “Stop”.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Notwithstanding any other statement within this privacy policy, originator opt-in data and consent will never be shared with any third parties.

Tips to Facilitate Approval of your TFN Verification

Submitting your TFN for verification is a simple process and the information you provide is pretty basic. Expect it to take 5 – 10 business days to complete. Unclear or insufficient Opt-In information and lack of documentation is where we see significant delays in the verification process.  So here are some tips!

First of all, we recommend you become familiar the appropriate consent level for your use case and implement an approved opt-in method.  Think through your messaging practices, your goals, and your patterns.  To learn more, please see our article Messaging Consent and Opt In Guidance.

When you contact us to discuss your Toll Free messaging and desire to have your TFNs verified, we’ll send you the spreadsheet.  Almost every field is required. Here’s what the columns mean and what the messaging aggregator is looking for.

Verify One Outbound Messaging Number

Only one sending TFN is allowed per company per use case as described above.

If your company has multiple office locations, and they each have one outbound messaging number, you can verify each number.  On the spreadsheet, enter one business location per row, and fill out the columns for each one.

Campaign Description

Describe in detail your use case and the purpose of your messages, like appointment reminders, receipts, etc.  Clear detail of your messaging purpose and who you are communicating with (prospects, existing customers, patients, employees, etc.) is very important.

Use Case Categories

You will select one use case category for your TFN.  Note the eligible and ineligible use cases below.  The sample messages that you provide will demonstrate how you utilize your use case category.

Eligible Use Cases

2FA
App Notifications
Appointments
Auctions
Auto Repair Services
Bank Transfers
Billing
Booking Confirmations
Business Updates
Career Training
Chatbot
Conversational / Alerts
Courier Services and Deliveries
COVID-19 Alerts
Emergency Alerts
Events and Planning
Financial Services
Fraud Alerts
Fundraising
General Marketing
General School Updates
Healthcare Alerts
Housing Community Updates
HR / Staffing
Insurance Services
Job Dispatch
Legal Services
Motivational Reminders
Notary Notifications
Order Notifications
Political
Public Works
Real Estate Services
Religious Services
Repair and Diagnostics Alerts
Rewards Program
Surveys
System Alerts
Voting Reminders
Waitlist Alerts
Webinar Reminders
Workshop Alerts

Ineligible Use Cases

High-Risk Financial Services Get Rich Quick Schemes Debt Forgiveness Illegal Substances/ Activities General
Payday loans
Short-term, high-interest loans
Auto loans
Mortgage loans
Student loans
Gambling
Sweepstakes
Stock alerts
Cryptocurrency
Debt consolidation
Debt reduction
Credit repair programs
Deceptive work from home programs
Multi-level marketing
Work from home programs
Risk investment opportunities
Debt collection or consolidation
Cannabis
Alcohol
Tobacco or vape
Phishing
Fraud or scams
Deceptive marketing
Pornography
Profanity or hate speech

How is the opt-in collected?

Consent cannot be acquired from a third party.  You must receive consent directly from the individual you will be messaging.

You will select ONE opt-in method from the following list. Be prepared to provide a screenshot or other documentation of your opt-in flow in addition to the description.

  • Voice/IVR Opt-In: In this case please provide a screenshot record of opt-in via voice in clients database/ CRM. (IE, a check box on their CRM saying that the customer opted in and the date)
  • Keyword or QR Code Opt-in: Provide image or screenshot showing where the customer finds the keyword in order to opt-in to these messages.
  • POS (Point of Sale) or Other Other On Site Location
  • Paper form: Please provide an image of the form.
  • Web Link / URL: Screenshots of the webform where the person adds their number and agrees to receive messaging.
  • Other: If your method is not listed, describe in detail how you obtain the opt-in. Provide a screenshot of this method.

An integral part of the approval process is effectively describing your opt-in flow (or how the opt-in is collected.) Make sure you can demonstrate that you receive the appropriate consent level for your use case.  To learn more about consent levels, see Messaging Consent and Opt In Guidance

Be prepared to describe the process you use in detail and provide documentation of your opt-in flow.

 

Additional Supporting Documentation

Documentation is required for all use cases. The carrier will not submit the verification request to the messaging aggregator until the Opt-In flow description and documentation meets with their approval.  Provide a URL to to the screenshot or image (uploaded to a sharing platform like Dropbox or Google Drive) or the webpage where they can see how you obtain consent (like a Contact Us webform with a consent checkbox.)

Sample Messages

Provide up to 3 variations of the messages that you send.  Here are some tips:

    • Make sure one sample is the most common message you will send.
    • Incorporate how you would message a phone number and a URL into a sample.
    • Make sure your samples demonstrate how your company messages within their use case.

You can simplify the samples by using generic placeholders for [customer name], [phone number], [date], [time], [url], etc. in place of specific information. You must redact your samples in cases of HIPAA compliance.  Here is an example of a redacted message sample:

Hello [customer name], just a reminder from [company name] that [patient name] has an appointment at [time] on [date] with [Dr Name] at [location]. Please reply Y to confirm and N to reschedule.

For URLs, you can use the [url] placeholder; however if you send the same link every time (like to your website or appointment page), include the full url in the sample.

Always Include Your Company Name:  Never leave your recipient guessing.  Your message must contain your company name in some way. Here are some examples:

South City Pediatrics: Your appointment for Dr. Smith is on Tuesday, May 3 at 2:40 pm. Please reply Y to confirm or N to reschedule.

Hi Debbie, we are happy to reschedule your appointment. A member of our team will give you a call, or feel free to call us at South City Pediatrics at [phone].

When will my TFN be SMS enabled?

We can enable SMS on your number right away, but no messages will be delivered to your recipient.  Our system will always pass your outbound messages to our carrier, but the mobile aggregator/mobile carriers will not deliver your message to the recipient unless the number is Toll Free Verified.  Until your submission completes and your number is Toll Free Verified, your messages will not be delivered.

What if my Toll Free verification submission is rejected?

If your toll free verification submission is rejected, we will receive a reason and will advise you on the steps needed to correct the issue.  Once the issue is corrected, then we must resubmit your toll free verification.

Questions or Concerns?

If you have questions or concerns about Toll Free Verification and the possible impacts on your messaging service, please contact us at support@inventivelabs.com.

Messaging Industry Resources

CTIA Messaging Principles and Best Practices
https://api.ctia.org/docs/default-source/default-document-library/170119-ctia-messaging-principles-and-best-practices.pdf

MMA Best Practices
https://www.mmaglobal.com/files/bestpractices.pdf

M3AAWG Best Practices
https://www.m3aawg.org/sites/default/files/m3aawg-mobile-messaging-best-practices-service-providers-2015-08_0.pdf

Telephone Consumer Protection Act (TCPA) Omnibus Declaratory Ruling (FCC 15-72)
https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.pdf

FTC Truth in Advertising
https://www.ftc.gov/news-events/media-resources/truth-advertising

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