Since publishing our last blog post on the future of shared short codes, we have received a lot of questions on how these upcoming carrier changes are expected to impact mobile organizing over long code. The most common question — what does this mean for my peer to peer texting program? 

Before we dive in, it is important to note the difference between A2P and P2P SMS traffic:

-Application to person (A2P)
Carriers classify SMS traffic as A2P if the messages are sent via an application or CRM tool. Messages sent via peer to peer applications are classified as A2P traffic by carriers, even though these services are often marketed as P2P.

-Peer to peer (P2P)
Carriers classify SMS traffic as P2P if the messages are sent from one person to another (a text to your friend) or a group of people (your family group chat).

P2P vendors often market their "peer to peer" platforms as an option to message lists that have not-opted in. However, carriers do not classify this traffic as P2P. Messages sent via P2P platforms are considered A2P traffic.‍

For many years, platforms marketing peer to peer services have operated in a regulatory grey area with the Telephone Consumer Protection Act of 1991 (TCPA) and Cellular Telecommunications and Internet Association’s (CTIA) code of conduct. The new carrier changes not only signal, but outline how carriers plan to crack down on the practice of sending messages to lists that have not opted-in. Carriers consider this traffic spam.

Are CTIA regulations the same as TCPA?

No. CTIA regulations are created and enforced exclusively by carriers. TCPA is a federal law enforced by the Federal Communications Commission. It is important to remember that even if your messaging is compliant with federal regulations, it may not be compliant with carriers.

10-digit long code phone numbers must register with carriers if they want to stay CTIA compliant. There is a grace period between March 1st and June 1st, 2021 for brands and organizations to register for their 10DLC. However, starting March 1st, 2021 messages sent via an unregistered 10DLC and/or to a list that have not opted-in are more likely to be flagged as spam.

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What is a registered 10-digit long code (10DLC)?
-Phone number that carriers associate with your brand. 
-Must provide general information to carriers about your use-case(s).
-Must be messaging recipients that have opted-in. 

The Grey Area for P2P Is Narrowing:

After March 1st, sending messages on an unregistered 10DLC can result in high surcharge fees, throttled send speeds, and worse, the potential for your messages to be blocked by carriers altogether. If you register your 10DLC and continue to message a list that has not opted-in, your traffic is more likely to be flagged as carriers only allow 10DLCs to message recipients that have opted-in.

If organizations don't take action to make their messages CTIA compliant, here are 4 potential consequences:

1. High fees

Messages sent via an unregistered 10DLC will incur additional fees. For example, AT&T will apply a $0.004 surcharge per message. 

We expect other carriers to follow this surcharge policy for unregistered 10DLCs.

2. Low send speeds

Unregistered 10DLCs will be able to send at a rate of 1 message per second. In the past, applications have gotten around throughput speeds by using a method called “snowshoeing”. Snowshoeing can be understood as the practice of cycling through multiple phone numbers to increase throughput and avoid spam filtering.

However, with these new carrier changes, the practice of snowshoeing puts your SMS traffic at risk for being flagged or blocked.

3. Unpredictable deliverability

Since all messages sent on 10DLCs (both registered and unregistered) will not return handset delivery receipts, there is no way to confirm that your message was delivered.

Carriers also reserve the right to filter and block messages sent via an unregistered 10DLC or to a list that has not opted-in. Not only will you be paying high prices for messages sent via an unregistered 10DLC, but there is no way to confirm that those messages are even delivered to your list.

4. Trust scores are your track record

Trust scores are assigned to your brand when you register for a 10DLC. Carriers will use these scores to determine your messaging class, throughput speed, and ability to provision registered phone numbers.

If a carrier flags your 10DLC or toll-free traffic ( i.e. messaging people that have not opted-in) your trust score will suffer and you may have trouble provisioning a new number in the future. The consequences of a low trust score include permanently lower send speeds and higher carrier fees.

Having an Opted-In Mobile List Is Future-Proof

Movements need to plan for a future without peer to peer tools, especially given these new carrier changes. An opted-in list will always be the long-term solution for organizations conducting a texting program.

Getting Opt-Ins Are Easier Than Ever

‍Many of our users have been able to rapidly grow their list by leveraging multiple opt-in channels.

Sync EveryAction/Action Network forms and Facebook Lead ads so your supporters can opt-in to receive SMS communications from your organization while filling out your form. Supporters can also opt-in via keywords. Quickly build your list by sharing your opt-in keyword during an event or on a social media post.

Strive tracks how your members opted-in, so you can easily target your messages by issue area, action type, geographical location, language preferences, and more!

P2P Style Inbox

The Strive inbox lets you convert automated messaging flows into one-on-one conversations.

Send a broadcast to your entire list or a segment of your list with a single click and let automations collect general info, ask questions, and announce updates. With Strive, you can build a mobile messaging strategy that is scalable, while still having the option to hold individual conversations efficiently.

‍Can I continue my peer to peer SMS program with a toll-free number?

No, a toll-free number can only message supporters that have opted in. While this may be a good alternative for higher throughput speeds, toll-free numbers do not offer local area codes and cannot be used for peer to peer texting programs.

When will my organization be impacted?

We don’t think these changes are going to be implemented like a light switch. Instead, these changes will be incremental as carriers’ filtering systems become better at identifying unregistered traffic or traffic sent to recipients that have not opted-in.

There is still a lot that is unknown. We will continue to post updates here as more information becomes available.

Key Takeaway:
In the short run, you may be able to get by messaging lists that have not opted-in, but the call to action has never been more clear: movements should start building their opt-in list now.

Want to learn more about Strive 10DLC or dedicated short codes subscription plans? Schedule a demo with a member of our Partnerships team.

About Strive Messaging: Strive is a powerful broadcast SMS tool used by organizations and campaigns around the world. We make it easy to scale your messaging while building relationships with your movement. Grow your base, mobilize your supporters, and deepen connections — all in one place. We’re innovating what texting can do, so your messages always make an impact. Strive only allows its users to send messages to lists that have opted-in.‍