Business at the Speed of Text

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Two-Way Texting Changes the Game

Put real-time text responses in your customers’ pockets and real-time access at your staff’s fingertips.

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Two-Way Texting Changes the Game

Put real-time text responses in your customers’ pockets and real-time access at your staff’s fingertips.

Find Out More

Business at the Speed of Text

Take a few minutes to watch how Solutions by Text can provide you with a compliant solution to enhance the customer experience and increase your bottom line through the power of texting.

Watch Videos

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Two-Way Texting Changes the Game

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A Guide To Important Texting Changes

Hear from Mike Cantrell and Amanda Payton of Solutions by Text as they walk through a number of important developments that have impacted the text messaging channel in recent months. Among the topics to be discussed during this webinar are:

  • Wireless Industry Overview
  • The Rules of Texting
  • Industry Changes
  • Texting Gateways, including Dedicated Short Codes, 10-Digit Long Codes, and Toll-Free Numbers

 


 

Transcript

 

Mike Gibb:
Hey everybody welcome. Thanks for joining us today. My name is Mike Gibb. I run accountsrecovery.net. And I want to welcome you to today’s webinar on A Guide To Important Texting Changes. Today, this webinar is being brought to you by Solutions by Text, you’ll receive an overview of the wireless industry, details about the rules of texting, how text messaging and the industry is changing, and details about texting gateways, including dedicated short codes, 10-digit long codes and toll-free numbers.

Mike Gibb:
As I mentioned, this webinar’s being brought to you by Solutions by Text. Solutions by Text is an enterprise business texting service built on the harder knowledge of best practices in the SMS industry with everything from complex delivery functionality to legal compliance. It’s primary focus is delivering critical information in an SMS format worldwide. Solutions by Text strives to develop a scalable solution with flexibility to meet industry changes in demand, maintain a functional user interface with various user access options, build products delivering a clear, consistent value, and can construct a suite of services matching the demands of the consumer.

Mike Gibb:
Before introducing our speakers today, I did want to take a quick second to talk about the accountsrecovery.net. Slack channel, I am going to put a link in the chat window. If you haven’t joined yet, I’m not sure what you’re waiting for. At this point, we’ve got about 700 members we’re using the channel to stay engaged, to stay connected. Just for instance, they were talking about regulation after the model validation notice. So I highly encourage you to click on the channel and join, completely free. Doesn’t cost you anything and start networking and staying connected with what’s going on.

Mike Gibb:
Now, let me introduce you to today’s presenters. Mike Cantrell serves as President for Solutions by Texts and oversees all aspects of operations for the company’s product umbrella. Mike has also been a public speaker in the mobile industry for more than 10 years, educating audiences on the most impactful and cost-effective means of communication today. Amanda Peyton is a Senior Vice President of Legal and Regulatory Affairs for Solutions by Texts. She obtained her bachelor’s degree in marketing with an emphasis on entertainment, media, and technology from NYU’s Stern School of Business and a law degree from the University of Kansas School of Law. Amanda was a litigator for almost a decade before transitioning to a career in the telecommunications industry. At Solutions by Texting, Amanda is responsible for monitoring legal and regulatory changes, developing implementation strategies, and ensuring compliance through employee and client training.

Mike Gibb:
The format for today’s webinar is going to be a presentation from Mike and Amanda. We encourage everybody to submit questions and we’ll get to them either during the course of their presentation or at the end, depending on the topic of the question that comes in. To submit a question, you can do so either by dropping it into the chat window or hitting the Q&A tab on your Zoom webinar control panel and sending it to us that way. With that, let me hand it over to Mike to begin today’s presentation. Mike.

Mike Cantrell:
Thank you, Mike. I’ll tell you it is always a privilege buddy to work with you and knowing this audience. And seeing the 100 of registrations for today’s topic just reiterate to me how important this SMS channel has become to the overall communication recipient of how brands and in this case, agencies communicate with their customers. So I can’t tell you what a privilege it is on behalf of my brother, Danny and I and our company as a whole to have this opportunity to educate and continue to educate this industry. For us, that’s what it’s all about because we want to protect the SMS gateways so that we can keep them open. And you guys can experience the success that SMS brings for you.

Mike Cantrell:
Now, my initial thoughts for you, guys, before we dive into a lot of content today. Amanda, we have a lot of content for you today. We have gone from, over the last several years to, can this industry text and our answer has been yes for years. And we have clients texting from this industry very successfully for years. And now the CFPB proposed rule change and came out a year ago. We’re just reinforced that. So the answer to that question has always been, yes, you can. You just got to make sure you’re doing it the right way.

Mike Cantrell:
And now the shift is, okay, we’re trying and we’re attempting to text now, but our messages aren’t delivering. So that’s why we came together and said we need to take the next step in education for the industry and explain to you guys in greater detail all the different text message delivery gateways and debunk some of what you may be hearing out there, and just make sure you have clarity on how to get your text messages delivered. As always, we talk about best practice. And then we want to make sure that you guys have a line of sight as to the proper implementation strategy. So that’d be in the case, I’ll hand it over to Amanda for any of her initial thoughts.

Amanda Payton:
Great. Thanks, Mike. So we really wanted to come together today and present this information to you all because there’s been a lot of misinformation across our industry about, can you text, can you not text? If you can text as a third-party debt collector, how do you do it? And so we really wanted to start from the beginning and give you some basics and allow everyone to have an understanding as to what are the rules of the road and what’s changed recently and what we expect to continue to change in the future. So we really hope that this will be informative and allow all of us to get on the same page and allow people to get some of these questions resolved.

Amanda Payton:
So, as Mike mentioned, well, both Mikes, please ask your questions. We’re going to really try today to make sure that if we don’t get to your question during the presentation, we’ll contact you. So we know a lot of people have a lot of anxiety about what’s going on in the industry and you all need these questions answered. So assuming we can get you an answer, we will.

Mike Cantrell:
So we’ve got a lot of content today and we’re going to work through this, but watch for your questions as well. And we put some slides together. So I’m going to go ahead and share my screen again. And we put some slides together to help navigate our dialogue. So Amanda, lay that foundation for us again.

Amanda Payton:
Sure, Mike. So I would say one of the most common pieces of misinformation that I get from clients or just from whoever we’re talking to in the industry is, well, we just need to worry about the TCPA or we just need to worry about the wireless carriers. And there are a lot of stakeholders involved in this industry and a lot of differing levels of how much influence they have over what we’re trying to accomplish through the texting gateway.

Amanda Payton:
So the first and the probably most prominent, most familiar stakeholders are of course lovely federal and state government. We’ve seen some dramatic changes in the TCPA landscape. Thanks to the Facebook versus Duguid case which the Supreme court decision came out last April. So that’s really changed the landscape for texting and whether or not you can do it. And if you can, what exactly are the parameters? So I get a lot of questions about this and that’s a topic that could take up an entire presentation. So if you have questions about that, please connect with me after this.

Amanda Payton:
So TCPA aside, we have the FDCPA and of course, Regulation F, which we’re thinking is going to have an effective date coming up here soon. That remains to be seen. We’ve got the FCC that at times will issue interpretations, final rules, or declaratory rulings interpreting the TCPA or interpreting other pieces of legislation to help us hopefully get some clarity on what the rules actually are. And then now we have state laws that have really started to become more prominent. California, of course, New York, Vermont, Nevada all have specific laws, whether it’s related to debt collection or to communication in general that are impacting our industry. So we’ve got a lot of stakeholders at the government level.

Amanda Payton:
And then of course, the wireless industry has Trade Association, which does so many great things for our industry and is really a strong lobbying force for us. The CTIA. And the CTIA gives us some really good guidance for what we can do over short codes. And then what are the best practices just for texting in general? Even if you’re not using a short code what are the rules? And at Solutions by Text, we take all of those principles and best practices and make sure that they’re incorporated into our software solution and best practices to us, our rules. We follow them.

Amanda Payton:
And then the biggest misconception is government and the CTIA is all we need to worry about. And I think we’ve seen over the past year or so, the wireless carriers are the ultimate sheriffs. I stole that from Mike. He says that all the time, and it’s so true. Ultimately if the government says we can text and our trade association says we can text, that’s great. But where we’re running into issues is, are the wireless carriers okay with what we’re trying to do and the content going over their network? And they have the absolute right to regulate that. And they issue a lot of rules that you have to follow that are just particular to each individual network. So again, at Solutions by Text, we treat that as a compliance mandate and we follow those.

Amanda Payton:
We also have aggregators that we work with that service the middle company between us and the wireless carriers, and they have their own acceptable used policies and their own set of rules. So there are a lot of different stakeholders involved. And what we do at Solutions by Text is take all of the varying regulations and rules that we’ve got to follow and put it into one comprehensive compliance program that your company will follow by being one of our clients. To Mike.

Mike Cantrell:
I’ll just add to that, Amanda, thank you. I think also what’s critical to understand is, not only do we provide you the guidelines for texting, we’ve incorporated into the design of the software. You have to follow these rules. They’re not optional. Well, one of the things you’ll hear us reiterate today on several occasions is, this is fluid. It’s changing. These carriers are committed to protecting these gateways. We’ll talk more about that a little bit more today, but also these carriers, in some cases, when we talk about the new gateways are on the same page with some things, but then they still have their own opinions or requirements for the same capability. And we’re going to talk about that again today.

Mike Cantrell:
Guys, they’re rolling this out at a enterprise level just like we do in our own businesses, we evaluate and adjust and evaluate and adjust. And even though they’re massive wireless carriers, they’re doing the same and we have to evaluate and adjust along the way, but they’re doing this for a valid reason and we’re going to discuss this more in our time together. So that being the case, help us understand a little bit more, Amanda, about one of the newest changes and announcements around shared short codes.

Amanda Payton:
Yeah. Thanks, Mike. So sticking with the theme of wireless carriers are the ultimate sheriffs of their gateways, back in 2018, it was kicked off by AT&T that no longer was AT&T is a network going to be supporting shared short codes. So it used to be that a company could gain access to a shared short code texts, their customers through it, and there would be many different brands sharing that short code. And the carriers back in 2018 led by AT&T said, “We want to stop this practice. And we want to find a way for every brand to have an individual originator.” And so every single brand is supposed to have an independent phone number.

Amanda Payton:
Now, that it sounds like a simple project. Okay, well, we’ll just get everyone set up with a phone number and take them off the shared short code. And it is not. It’s become a very, very detailed massive overhaul of the system. And the carriers have told us, “Look, we will align the deadline to get everyone off of the shared short codes with the availability of 10DLC becoming commercially available so that each company on that shared short code has the ability to have a number that will work and be fast and have all of the attributes that they need to get their business handled.”

Amanda Payton:
So back in March of 2021, 10DLC became commercially available. I know we’ve put out quite a bit of information about 10DLC and we will continue to do so because as Mike said, this is fluid. This is a very, very large overhaul of the complete wireless carrier network. So this has been a really big change. We are being told that it’s going to be sometime in Q3, Q4 of 2021, that the shared short codes will no longer be available. Right now, we’re in this transition period where we’re being given time to take the brands off of the shared short code and get them onto a 10DLC or dedicated short code, which we’ll talk about later. We are being told that that data is flexible right now and really depends on the progress that is being made. And so we’re working with the wireless carriers and checking in on this project because I think everyone came to realize it’s a lot bigger of a project than it was expected at the beginning.

Mike Cantrell:
Yeah, and not only is it a significant paradigm shift, it is a massive lift. Now, it is already underway. Now, they may be moving the goalpost, but you don’t have a choice. So, from origination, if you’ve ever had any interaction with Solutions by Text, we’re all about the short code because the short code was designed for business to consumer texting. I’m going to talk a little bit more about that in just a moment. But I want you to know that many of these adjustments, this paradigm shift that’s happening with the carriers is based on an umbrella or an overarching objective of which we are in agreement with. And that is protecting this SMS gateway. They do not want to let what happened with email happen with texting. And we still get very little spam in the texting gateways and they are committed to try and do preserve that of which we are major advocates of. And we do our part in great detail by the design of our software.

Mike Cantrell:
Now, as far as this overarching goal of protecting the gateway, we’re certainly going to do our part, but this shift comes now more to making sure we understand the difference between short codes, 10DLC, and toll-free numbers. Now, where we previously had thousands of customers on shared short codes, folks, understand that technology impacts every industry and every walk of life and it does here as well. So what’s happening is, the carriers in their efforts to preserve the integrity of the gateways, they are incorporating new technology around auditing and combining that with AI.

Mike Cantrell:
So as this scales, they can crank up the auditing robots to make sure they have a line of sight as to who may be compromising the rules and they can automatically disrupt service. And they’re doing this on a large scale. If you’ve got thousands of hundreds or thousands of brands on the same short code, they can delineate. So now, the option will be either a dedicated short code, or 10DLC, or a toll-free number. And if everyone has to have their own. Now they can accomplish this goal of mass auditing and automating disruption of service. Well, that’s one of the reasons why we’re having this webinar today because that automation that I’m describing to you is already in play and the result is, more and more of the messages are failing for those that aren’t executing based on these carrier requirements.

Mike Cantrell:
Now, we’re going to talk about this a little bit more than I’ll ask Amanda to share some additional color on this. Let me begin right here in the middle as far as your overview and understanding of the current gateways. Now, I want to make sure this audience has clarity on the difference between what we’ve seen in the marketplace that’s referred to as long codes versus what Amanda is now referring to as a commercial, our enterprise solution called 10DLC.

Mike Cantrell:
Now this long code world was designed for peer-to-peer texting. Now we see long codes used on large scale by organizations, but it’s designed for organizations that are executing peer-to-peer texting. And the greatest example of that would be Uber or Lyft. The ability for the driver to text the customer and then not see each other’s cell phone numbers is going through what’s called a proxy and you’re seeing massive text message delivery on long codes, but that message delivery by category meets the requirements of peer-to-peer.

Mike Cantrell:
But because there is an increased cost, and we’ll talk about that more with short codes, and you can get these long codes turn on faster, many of the brands started rushing into the marketplace, “Man, we’re going to do texting. It’s working.” And those brands were trying to use long codes for business to consumer texting. And that’s not what the peer-to-peer gateway was designed for. So as a result where there may have been success early on, the more they crank up these auditing robots, the more this messaging is beginning to fail.

Mike Cantrell:
So having that clarity, and because they have this overarching objective of having a line of sight as to every brand that was texting on each phone number, all the carriers finally came together and said, “Okay, the way that we’re going to have to do this is we got to move away from these shared short codes.” And we’ve got to provide what they’re calling 10DLC. Now, certainly it’s still 10 digits, but there’s a difference. There’s a difference because with the short codes, it’s a much more of an arduous process of getting those short codes provision. There’s briefs, they’ve got to know the brands, they got to know the EIN number of the company that’s texting over that. And these were some of the requirements of short codes since inception, but it’s now the requirement of 10DLC as well.

Mike Cantrell:
And that’s what makes this more of a commercial solution because this submission of the brief process, you can’t just have 500 long codes sitting on the shelf and grab one off the shelf and plug it in and start texting. If it’s commercial-based, then they’re going to control it. There is company detailed requirements for submission, and the carriers will know every company that they’re auditing and what messaging is going through those numbers and the organization they’re texting over those numbers so that they can hold not only the brands, their providers like Solutions by Text, and Amanda, you alluded to, these aggregators, the middle people, we’re going to hold everyone accountable. Why? Because we want to protect the gateways of which we’re advocates again, folks, and this is fluid. But right now everybody’s still reads all their text messages. And that’s why it’s so critical that this industry has this clarity that we’re providing today and then adheres to it.

Mike Cantrell:
Now, the other option is a dedicated short code. And we’re going to talk more about the difference between the two and the difference in cost and so forth as well. But I’ll answer this in advance. Yes, the dedicated short code is more expensive. Yes, it takes longer to turn on, but there are some benefits of the dedicated short code or the short code because this is the gateway that they designed for business to consumer texting. So there’s still some benefits of that. And we’re going to talk about that a little bit more today.

Mike Cantrell:
Now, I’m going to hold off giving you guys more information on toll-free numbers because Amanda’s going to talk about this in greater detail in just a moment. Let me transition just a bit to talking more about a comparative of these dedicated short codes versus 10DLC, but I’ll pause here. Amanda, I know that was a lot of information. Any comments or thoughts before I continue?

Amanda Payton:
All right. Just one thought, Mike, just thinking about the effects of the Facebook case and I got a lot of feedback from clients after the decision came down saying, “Well, now we can text whoever we want. We can do whatever we want.” And think it’s really important to understand that the CTIA guidelines that we follow tracks the TCPA’s language.

Amanda Payton:
So what I keep telling our clients after the Facebook cases, these gateways are being watched through a microscope. So it’s business as usual over here as Mike has mentioned, the technology surrounding 10DLC and dedicated short codes and the audit functions, we are under a microscope right now. And I don’t see that ending anytime soon. So like I said, Facebook case’s a topic that could warrant its own webinar and has over the past couple months. So just wanted to throw that out there. It’s not a free for all after the Facebook case. And I think that’s becoming more clear as time goes on. This 10DLC is very, very highly regulated.

Mike Cantrell:
And will be evaluated and adjusted and evaluated and adjusted along the way. So I want to give you guys a little bit more education and clarity on the difference between the two. Obviously a dedicated short code is five digits that can be six digits as well. It can spell something, but I don’t recommend that you do that unless you’re doing a great deal of advertising around keywords, but they do have vanity short codes as well whereas the 10DLC is a 10-digit number. The dedicated short code can be customized if you’re going to go for a vanity code, it should be more around an easier to remember short code like 345345. But for most of the texting that you guys will be doing, there’ll be outbound texting, and it’s not necessary that you have that easy to remember code. Whereas the 10DLC, you can request a specific area code, but it’s not guaranteed.

Mike Cantrell:
Now, here’s one of the biggest differences. The provisioning time of a dedicated short code is eight to 10 weeks. Now, we’ve got this process down to a science. There are times depending on the workload of the carriers and the aggregators and everybody involved in this process that we see short codes come live in. Man, I’ve seen them come live in five to six weeks, but there’s no guarantee.

Mike Cantrell:
So as you’re planning and you’re adding texting to the way you’re executing business, we always recommend, especially for our large clients in parallel, get your short coat in the oven. And while that short code is being provisioned, now let’s work on your implementation strategy, all your business rules and how you’re going to do your opt ins, and what are the message templates say, and where the URLs take them. You can do this in parallel. But just have this clarity on the amount of time. So eight to 10 weeks is what you should plan for. But we’re seeing those codes come on much faster.

Mike Cantrell:
Now, three to four weeks is where we began in the 10DLC world? Well, evaluate and adjust. And now we’re seeing that on the average to be less than a working week, five business days. Now, we still say two weeks, give us some wiggle room because there’s still things out of our control with the carriers and aggregators. So three to four weeks, I would say you can shorten that now down to 10 business days. And now, depending on what all’s going on, we’re seeing 10DLC and they’re working to streamline this process as well. It’s new and as message. But we’re seeing that come on faster now.

Mike Cantrell:
Now, here’s one of the biggest differences. And when you’re looking at this check chart, your eyes are going to go to two things that make dedicated short codes very different than 10DLC. And one is granular message delivery. Now, I’m going to resist the urge to really getting down in the weeds here, but I think this is information you need to know. Because short codes were designed for business to consumer texting, the carriers are charging surcharges additional fees for brands to text over these gateways. But to get here is also more granularity on what happened with the message because large brands, and really my recommendation to you as your consultant, because of the massive cost-savings and prove execution of your business model with texting, you can easily justify a dedicated short code even for smaller operations because it’s critical.

Mike Cantrell:
And one of the key things here is, confirmation of your message delivery, we get very granular returns from the carriers that if you attempted to send a message and they needed a top up their phone, or it was temporarily suspended because they didn’t pay a bill and that message didn’t deliver or things of that nature, we get that information from the carriers on a short code. But with 10DLC, we don’t. All we’re going to get from them is, that was a valid cell phone number. You gave it to us and we sent it to the device. And that’s all we’re going to get back from the carriers.

Mike Cantrell:
Now, there’s also some volume limitations. We’ll talk a little bit more about that as well, but these carriers are different and some have different rules for their 10DLC world. And one of the decision points as you’re trying to decide dedicated short code versus 10DLC is, first of all, isn’t an option for the industry that you’re in. Amanda’s going to talk about that a little bit more in just a moment. But then how many messages am I sending? And are there volume restrictions?

Mike Cantrell:
And we’ll talk about that a little bit more as well. And then the other main thing, especially for the arm third-party industry, 10DLC does not support FTEU. And as you guys well know the T-Mobile Code of Conduct that identified the industry as having disallowed content. Amanda will talk a little bit more about that in a moment now. We’ve been able to overcome that. So just once you, guys, to have that clarity on the difference between these two gateways, detailed granular returns, volume capabilities, and FTEU. I’ll pause there. Amanda, and see if you had any additional thoughts or comments.

Amanda Payton:
So Mike, just wanted to piggyback on the volume and speed restrictions. One of the most revolutionary parts of the 10DLC world is that the carriers are actually using an outside organization to run a company that applies for a 10DLC through a vetting process. And Mike, I know you touched on that, but it’s been really interesting because I help with that at Solutions by Text and I’m seeing the scores and I’m looking at websites and trying to figure out why was this company scored lower than someone in a similar industry. And there’s not really a lot of available information about this process and we’re learning more about it as time goes on, but if you’re wondering, well, what is my speed restriction going to be? What is my volume restriction going to be? We don’t know that until we submit the application and until your company is actually looked at through the registry that they’re currently using,

Mike Cantrell:
Amanda, I appreciate you touched on that scoring model. Again, we’re on a very large volume scale adjusting now the delivery of these capabilities in the introduction of 10DLC and we’re adjusting on the fly as well to overcome any, first of all, getting these codes turned on, but then volume restrictions. So I think what’s really important is now that you, guys, have a little bit more clarity on these different gateways. Now, I’m going to let Amanda take us through a little bit more understanding of the impact on specific industries. Amanda.

Amanda Payton:
Okay. Great. Thanks, Mike. So let’s start with the dedicated short codes. As Mike said, this is really what we encourage our clients that can justify the cost. This is what we encourage you to get on. It’s a little more complicated to get it set up, but once it’s set up, it runs a lot smoother. You’re able to get so much great information from the carriers at this time. And our hope is that eventually 10DLC will get to that level too, but we’re quite a ways off from that.

Amanda Payton:
So, what has happened is, since the vetting process is so significant and takes a lot of time, requires a lot of back and forth between our company and our aggregator, the dedicated short code has become the preferred gateway for many industries. And really, I think in the carriers eyes, they’re not going to come out and say, “This is our favorite gateway,” but they like this.

Mike Cantrell:
It is.

Amanda Payton:
They like companies on short codes. They tend to go through the vetting process at the beginning and then we don’t really hear a whole lot. Of course, we make sure our clients have any necessary compliance put into place before their codes go live. And we don’t really hear a whole lot. Whereas on the 10DLC world, it’s a little different. They’re looking at these messages every day and we’re getting feedback from the carriers on this company is doing this and so on.

Amanda Payton:
So what happened with T-Mobile back last November, T-Mobile had a code of conduct update. And came out at Section 5.2 of the Code of Conduct, they listed some industries that they said contained disallowed content. And of course, the reasoning was, they looked at industries that were resulting in high spam complaints. So a high number of spam complaints. And that was very concerning to the carriers and especially to T-Mobile. So T-Mobile’s decision via their code of conduct was, if you were using, or if you are part of any of those industries that were listed, you can’t text on the T-Mobile network, which of course, had a very significant impact on our clients, especially debt collection, the high interest, installment loan world. Very, very, very scary time for us as an industry.

Amanda Payton:
But T-Mobile in the code of conduct said there’s an exception process. And so at Solutions by Text, we got to work on that and we said, “Look, we’ve got to find a path forward because we represent good quality companies.” And the most important thing is, their clients want these messages. We don’t have high opt-out rates. We don’t have people saying this is spam. We just don’t have that. And if you give us an opportunity to show you that and to show you the data that we have, we think that we’re going to have a different… We’re going to have a better understanding as to what these industries are actually doing. And as we continue to have those conversations, we got T-Mobile to a point of comfort with the debt collection industry. And as a result, we’ve got an understanding what T-Mobile at this time on how debt collection companies can text using a short code and the requirements that go along with that. So Mike, I don’t know if you have anything to add to that.

Mike Cantrell:
Yeah, I’ll just add to that that when you couple all this together that Amanda’s describing to you, these compliance requirements and T-Mobile’s physicians, some of it to be quite honest with you, it was perception, but others was legit because the industry was just beginning to realize the success of communicating with consumers by text about their past due accounts. So it was creating some spam because some operators were running into it with wrong information and it was triggering some complaints.

Mike Cantrell:
So it was just easy for them to make blanket decisions. Now, fortunately, we had years of data of clients that have been doing it the right way over short code. And that’s what allowed us to overcome their position. Now, at the same time, though, you got to have clarity of knowing that there is nothing more significant than monitoring. Let me say it this way. There’s nothing more significant than managing the consumer permission for texting. When you combine the federal oversight with the CTIA and now the carriers, the penalty, the fine for an unsolicited text message is $1,500 per message.

Mike Cantrell:
Now, when you look at the volume and massive scale of messaging that’s happening out there, that number is significant. And unfortunately, early on, there were some huge brands they got slapped with some huge fines because they weren’t getting the right consent. They weren’t documenting the consent. You can’t just say, “Well, I’ve already got this permission. So I’m just going to start texting.” You have to have documentation of their consent, their permission by text. That has to be part of the history of texting.

Mike Cantrell:
And then you have to be monitoring the disconnects. For us, we call this Text IQ at Solutions by Text. It used to be 90 to 120 days that someone could turn their phone off. And then that number be reissued to someone else. Now, it’s shortest three days. You need to have a solution on how you’re managing these disconnects. All this is just so critical. And this is a foundational to Solutions by Text and how we’ve been successful in our relationships and our rapport with the carriers. Amanda, I’ll let you continue thoughts around requirements. And then we’ll talk about dual delivery as well.

Amanda Payton:
Okay, great. Thanks, Mike. So just dedicated short codes overall, we’ve already covered this, they are more costly than 10DLC. And there’s a lot of reasoning behind that that we’d love to have a conversation with you about further, but we have to purchase a short code. And so there’s a provisioning fee associated with that. And then we have to continue to lease the short code through the United Short Code Registry. So we already discussed they’ve got some additional rules. The CTIA has its own guidebook for short codes called The Short Code Monitoring Handbook. So they’re more complicated. They’re definitely… There’s more of a process to get one up and running, but once you do, it’s a very smooth process generally. Or if there is an issue, we’re given time to fix it. And we don’t see a lot of problems after the short codes go live.

Mike Cantrell:
And I’d like to share an additional thought as consultants to this industry. And again, what a privilege it is that you guys are giving us your time, so many of you on this webinar today. What I would share with you is that our experience has been, even though the dedicated short code is more expensive to provision and maintain, I get it, but the proper implementation strategy, the improved execution of your business model, regardless of the size of your organization far outweighs the cost of what these dedicated short codes costs. In addition, when you do a full-blown implementation of smart URLs in your text message to offset postage costs, now that postage savings dwarfs the cost of not only the dedicated short code, but everything you’re doing with Solutions by Text.

Mike Cantrell:
So it’s, as you guys can tell, I’m a huge advocate of dedicated short code. Now, I want to make sure this audience has clarity. The third-party industry, your only option, even though we’ve talked a lot about 10DLC today, your only option is the short code. Now, T-Mobile is MetroPCS and they recently bought Sprint. So that’s one-third of the cell phone devices in the marketplace. This is their position. And the only way you can text their consumers is on short code. It’s the only option.

Mike Cantrell:
Now, 10DLC, we’ll talk a little bit more about that in a moment, but if for many of our clients, they’re servicing both first-party and third-party. Now, is first-party and option for 10DLC? Yes, but still even our largest client partners that are servicing the first-party industry, it’s a dedicated short code. And then underneath that is a 10DLC because there are some month-to-month plans or [inaudible 00:42:13] phones that may reject the message on the short code and our software automatically rolls to a 10DLC. And for that first-party industry, there’s really not a number out there you can hit, but it’s combining now the efficiencies of more than one gateway. I could go on to that, but that’s more of what we call dual delivery. We’re going to run out of time before we know it.

Mike Cantrell:
So let me talk a little bit more about this 10-digit world and give you a little bit more line of sight. The 10-digit world, 10DLC, for many of our clients in first-party that are servicing multiple brands, certainly you can consider 10DLC, but every one of the brands that you’re servicing for has to have their own. You want to make sure that it can be used down… We’re seeing all kinds of use case down to a different 10DLC per location so they can detail analytics, man, because the numbers don’t lie, or each one of the brands that you’re servicing for has to have their own 10DLC. Certainly the 10DLC is more cost-conscious and it is a legitimate gateway for first-party, but it’s not an option for third-party. If you need to get started a little quicker, we talked about that as well.

Mike Cantrell:
Now, the limitations is that lack of reporting that we talked about. The carriers are still finalizing the speed and volumes and so forth. But the other thing is, if you aren’t doing any keyword activity, telling someone to text a keyword to a 10-digit number is clunky. So I’m just giving you some thought process on this critical decisioning that you’re making around what gateway that you will choose and use for your SMS activity. Now, I’m going to roll on the toll-free numbers and see if Amanda has any additional thoughts around there. But you know what, before we go there, Mike, I’ll lob it out to you to see if there’s any comments or questions coming through so far, buddy?

Mike Gibb:
Sure. The one question I have that is the last now is just SBT managed disconnects, verify that no disconnect or reassignment of a number has occurred since the last consumer’s text consent. If a disconnect reassignment has occurred first ask for another text consent.

Mike Cantrell:
Yeah, you know what? That’s a great question. So let me go into that just a little bit. Once a consumer has provided permission to text, that triggers a monitoring service and Solutions by Text as part of our TIQ Service. So now we’re monitoring that cell phone number. We get this massive data from the carriers every night. And if that number comes back disconnected, that’s like a stop command. So we’ll notify you so you can update that record on your side, and this should trigger a workflow on your side because not only if you try to text it again, we would fail it. That’s not your customer anymore. So now that should trigger a workflow. You need to take these numbers out of your dialers. It’s not your customer anymore. And how do I get in touch with this customer and get the new cell phone number?

Mike Cantrell:
In addition to that, Mike, based on that question, because of this massive data that we’ve aggregated, many of our clients say, “Here’s a phone number and this is the date that the account originated. Can you tell us since that day to today, if that number has been disconnected, if there’s been a right party contact change?” Yes, we can. We don’t have time to get into details. We may if Amanda has time at the end to talk about what is to call pass through consent in the industry, but yes, we have the ability to monitor disconnects and yes, you can look backwards to see if there’s been a right party contact or change or a disconnect since account inception. That was a great question. But you know what, let’s flow back out here and talk about toll-free numbers a little bit more, Amanda. Okay?

Amanda Payton:
Sure. Just real quick, Mike, I think I saw a question come through about the reassign numbers database and the answer is yes, once that is available, we will absolutely be using that data and be a user of that service. So we are monitoring that situation and the creation and implementation very closely. But right now we get the same information just from different ways.

Amanda Payton:
So toll-free numbers… We’ve been getting a lot of questions about toll-free numbers. People are saying, “Well, if I don’t want to dedicate a short code and a 10DLC doesn’t seem like a good option for me. Can we still get on toll-free numbers?” And the answer is no. Unfortunately not. And the reasoning behind that is because there’s been so much focus and dedication and to creating the 10DLC world and making sure that it works for businesses, that we are seeing toll-free numbers not get the delivery rates that we used to see. It’s just not a preferred gateway anymore. It’s very, very difficult to use and the results are not there.

Amanda Payton:
So as a company, SBT is not offering toll-free numbers as an option anymore because of the availability of 10DLCs. Internationally toll-free numbers are still a solution in some areas. And so we still do have that ability, but as far as the United States numbers, we are focusing on the 10DLC effort. Now, some people have come to us and said, “I already have a toll-free number and I understand toll-frees don’t get great delivery. Do we have the ability to text to enable it if we want to?” And we do have that ability, but a misconception, I think in the marketplaces, if I have a toll-free number and I text enabled it, I have a 10DLC. And that is not the case. If you have a toll-free number and you text enable it, it’s still a toll-free number and it still has the limitations of a toll-free number. So we’ve had some clients come to us and say, “I want to text enable my number.” And I think every time we’ve ended up doing a 10DLC instead.

Mike Cantrell:
Exactly.

Amanda Payton:
It’s just a better solution because of delivery of speeds, reliability, and the cost is also very reasonable when you break it down. And we’d love to have further conversations about that if anyone has any specific questions on that.

Mike Cantrell:
I’ve said once again, the overarching objective of this session and our time together today is educating the industry on these gateways and helping you guys understand how your message is… How we can help you get your messages delivered. Because we are seeing a lot of time and money and technical efforts being put forth around turning on the services. And at the end of the day, your messages aren’t delivering or only a portion of your messages are delivering. And you don’t have the details around that and the ability to monitor disconnects. So Mike, before we began to move into our closing thoughts or comments, I know this is a lot of information today. I’ll come back out to you to see if there’s another question or two to see that we can answer today before we move into our final thoughts.

Mike Gibb:
I think we’re good. I think you’ve addressed this, but there was a question that came in earlier on how you’re handling carriers pushing collection messages over free to end users short codes. And are you using standard short codes and/or long codes today? Yeah, I think you’ve addressed that. That’s really the only other thing I see right now.

Mike Cantrell:
Yeah, so we get a lot of questions about free to end-user and the answer is with the T-Mobile exception, FTEU for T-Mobile MetroPCS and Sprint is a requirement. And there is a way to do both FTEU and Standard on the same short code to accommodate the other carriers and minimize the cost as much as you can. And it’s been solutioned. Okay. So if there aren’t any additional questions, let me just provide some closing thoughts and then we’ll let Amanda close out our time together as well today.

Mike Cantrell:
Let me just begin my closing thoughts with where I began today, and that is, thank you. I am watching the participation here today, and you guys have hung in here the entire hour with us. So let’s just reinforces how important this topic of discussion is and what a privilege it is for us to be that subject matter expert and educate the industry as a whole.

Mike Cantrell:
Now, once you understand… Now that you have clarity on these different gateways and understand which gateway you’re going to have to provision depending on first versus third versus a combination of the two, there is so much massive savings and efficiencies with your implementation strategy. We’re going to have to save that for another webinar, not today.

Mike Cantrell:
But let me just share with you, and I’m just going to tease you a little bit. Because of the developments and evolution of what’s going on in the SMS gateways, the ability to prompt your customers to reply with images and those images coming over encrypted gateways so that they can be encrypted in transit and it rests so that if there’s an instance in your business model where you’re asking your customers to scan and email you something because you need some kind of image, that can be done over the texting gateways. And it’s releasing bottlenecks in many of our clients business model. But the utilization of smart URLs is the most groundbreaking efficiency that we’re seeing. Your consumers want to self-serve.

Mike Cantrell:
Just putting texting in the place is an effort towards expanding what we’ve always done. And many organizations are stuck in that, but now they’re adding texting and they know that they need to diversify. Now, within the diversification of texting, only allowing them to call you, okay, that’s what you’ve always done. Now you need to expand that. And I’m telling you that 100 to one, if you put a smart URL or a short URL in the message, and you give them the choice between calling you or clicking the URL, they want to self-serve. They’ll click the URL and you can track that activity. These URLs can also be unique to offset massive postage costs. I want to talk about that on another webinar as well. So beyond the deliverability, there are some awesome efficiencies and wins in the implementation strategy. We’ll save that for another webinar for another day. Amanda, any closing thoughts or comments?

Amanda Payton:
Sure. I think where people that I talk to and companies that reach out, how do we get all of these best practices and laws and everything that we need to follow that continuously changes? How do we get all that together? And how are we making sure that we are compliant and following all the rules? And that’s a conversation that we’d love to have the opportunity to show you our software solution because as these compliance changes happen, we don’t just say, “Hey client, you’re responsible for making this change.” We are implementing the changes as they go. So if you have questions about best practices or how as a particular industry, you can start texting, please reach out to us. It’s not always a simple conversation to have, and it’s pretty detailed. So we would love to show you that and really walk you through how we do things at Solutions by Text.

Mike Cantrell:
Thank you for that, Amanda. Mike, I’m going to come back to you, buddy, right here under sliding in at the finish line. Once again, an hour just disappeared, man.

Mike Gibb:
Does. Well, listening to the two of you and you make it go by really fast. So you guys did a great job. We did have one last minute question that came in under the wire and that is, is your product scalable based on agency size?

Mike Cantrell:
Oh, listen, you want to talk about horsepower? There is not a brand or a size of an organization that we can’t accommodate. So we have a substantial footprint in the auto finance and banking industries and some of the largest brands that are out there in the marketplace are using us. We just been very fortunate with that. But more importantly to that question is, we have progressive strategies. You can come in and just get started with a pilot program regardless of your size. And then as you scale, there is built in savings. But in this industry, we’re already servicing some of the largest brands in this industry. So there is certainly no capacity or volume limitations and what we can do. So thanks for that question, Mike.

Mike Gibb:
One more. Under Reg F when in effect, is a short code still allowed?

Mike Cantrell:
Amanda.

Amanda Payton:
Yes. Yes, it will be. And again, that’s focusing on Regulation F. Even if other gateways were allowed, the carriers are only allowing it via short code if you’re a debt collector. So yeah, the short codes are still going to be allowed. And it’s the only way that you can text.

Mike Gibb:
Great question. You’ve got a definitive answer from a lawyer. So even double bonus for that.

Amanda Payton:
I really wanted to say it depends, but save that for another day.

Mike Gibb:
Excellent. Well, Mike, Amanda, before I get into my closing spiel, any last minute wrap up any last minute takeaways that you want to give our audience?

Mike Cantrell:
Well, I think we’ve covered it in detail. And I just appreciate everybody hanging in there with us today. Thanks, Mike.

Mike Gibb:
Excellent. Well, thank you, Mike. Thank you, Amanda. Thank you Solutions by Text for sponsoring today’s webinar. If you didn’t see, I’d put a link in there in the chat. If you’re listening, go to solutionsbytext.com to learn more about the company. I highly encourage you to do that. Thanks again to everybody for your participation and watching and listening today. We’re back tomorrow talking about probate recoveries. If you haven’t signed up for that, there’s a link in the events calendar on accountsrecovery.net. So I hope to see you back for that. Until then everybody, enjoy the rest of your day. And we’ll hope to see you back soon. Mike, Amanda, thank you very much again.

Amanda Payton:
Thanks everyone.

Mike Cantrell:
I’ll let you, guys. Talk to you soon.

Amanda Payton:
Take care.

Mike Cantrell:
Bye now.