If you are the owner of a telemarketing business, there is a good chance that you are familiar with The Campaign Registry (“TCR”). TCR registration is essential for businesses for several reasons. Crucially, it ensures that text messages routed through a virtual phone service provider (“service provider”) reach their target audience. For the uninitiated, a service provider supplies businesses with phone numbers that are not associated with a physical line or SIM card. Rather, the virtual phone numbers operate in the cloud, thus allowing businesses to send and receive calls using an Internet connection.
Many virtual phone service providers are already requiring that their clients register to continue utilizing their services. Eventually, major mobile carriers will require that all virtual telephone numbers, even if used for conversational texting, become registered on TCR.
What is TCR?
TCR is a collaboration between major mobile carriers, including AT&T, T-Mobile, and Verizon, set up to address the delivery of certain categories of text messages. TCR registration ensures carriers that text messages originate from legitimate sources, such as two-factor authorization (“2FA”) verification or appointment confirmation vendors, and traditional retail businesses.
It is important to note that the business itself does not actually register with TCR. A business will instead provide all relevant information to its service provider. A service provider will work with its client business to successfully register the business’s 10 DLC, or 10-digit long code virtual phone number, on the TCR website.
What Information Will a Service Provider Ask For?
Service providers will request a good amount of information from their customers, including their brand names and foreseeable SMS campaigns, before beginning the TCR registration process on their behalf. Among other things, service providers will ask for information about:
- The business (i.e., legal business name, business tax number, contact information, and website URL);
- The subject text message campaign(s):
- The type of product or service provided by the business;
- How the business acquired consumer consent for the receipt of text messages;
- Estimated message frequency;
- Samples of text message content;
- If text messages contain hyperlinks, full text of embedded language (such as Privacy Policy and Terms of Service); and
- How the business ensures that it honors consumer opt-out requests.
What Content is Restricted By Major Carriers?
To reduce consumer exposure to unsolicited text messages, mobile carriers will not grant TCR registration to businesses that promote certain prohibited content. Prohibited content includes, but is not limited to:
- High-risk financial services;
- Debt collection or forgiveness;
- Gambling and illegal substances; and
- “Get rich quick” schemes.
Why Should Your Business Obtain TCR Registration?
Text messages sent in violation of TCR regulations may result in fines per individual text message. Registering virtual telephone numbers on TCR ensures that your messages are more likely to reach your target audience, as opposed to being flagged as spam. TCR registration also offers peace of mind, ensuring that your SMS campaigns will not result in massive fines or regulatory enforcement action.
TCR registration is only one of the many steps that a company can take in order to ensure compliance with various telemarketing statutes, such as the Telephone Consumer Protection Act (“TCPA”) and Telemarketing Sales Rule (“TSR”). The attorneys at Klein Moynihan Turco provide clients with TCR registration assistance and draft their requisite Privacy Policies and Terms of Service. Our attorneys also advise clients on all manner of regulatory compliance and defend clients in TCPA class action lawsuits.
If you require assistance with telemarketing law compliance or related litigation defense, please email us at info@kleinmoynihan.com or call us at (212) 246-0900.
The material contained herein is provided for information purposes only and is not legal advice, nor is it a substitute for obtaining legal advice from an attorney. Each situation is unique, and you should not act or rely on any information contained herein without seeking the advice of an experienced attorney.
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Photo by ROBIN WORRALL on Unsplash
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