Telecom Regulatory Updates

Providing businesses with essential compliance tools to earn trust with customers and prospects

Our Commitment to Combating Spam

The telecommunications industry will soon be implementing regulatory changes which CallTrackingMetrics is committed to supporting as part of a global effort to combat fraudulent spam calls and text messages. The two changes, the Application to Person messaging service, also known as A2P 10DLC, and STIR/SHAKEN, will require businesses to obtain an attestation trust score by creating a business profile. The trust score provides the underlying carrier with information to verify that the communications are not spam.

Across 2021, businesses will be assigned a trust score for outbound calling, which will be “signed” by the underlying originating caller’s carrier and sent to service providers or mobile networks like AT&T, T-Mobile (including Sprint) and US Cellular. There will be different ratings, or attestations, of calls: A, B or C. These ratings allow carriers to verify information about the call or text message and give consumers a better idea of the validity of the caller. “A” rated calls are likely to be treated favorably, while “B” and “C” rated calls will be viewed as more suspicious. Over time, the weight given to attestation ratings is expected to increase according to some carriers.

Read on for more information on what you can expect from these changes, what will be required, and how your business can maintain compliance.

STIR/SHAKEN Business Registration Forms Now Available

Complete by: June 30
Visit the Trust Center

Registration for Application to Person messaging service (A2P 10DLC) is coming soon.

Business Profile Registration FAQ’s

What are the requirements for business registration?
  • Business Name
  • Physical Address (Street, City, State/Province/Region, Postal Code, Country)
  • Business Identity (Direct Customer or ISV/Reseller/Partner)
  • Business Type (Sole Proprietorship/Partnership/Corporation /Co
  • Operative/LLC/Non-Profit)
  • Company Status (Private/Public)
  • Stock Ticker & Exchange (if Public)
  • Business Registration Number & Type (DUNS or Business License)
  • Industry
  • Website
  • Regions of Operations
How do these changes affect me?

These regulatory changes are industry wide so businesses will need to register their phone numbers for the business profile to obtain a trust score for both STIR/SHAKEN and A2P. For A2P messaging, there are additional steps that are needed to register your Brand and campaign/use case (additional fees will apply) which the carriers will need to approve. Campaign approval can take up to a week. As soon as additional information is released from the carriers we will post updates here.

Why are the carriers making these changes?

With these industry changes, part of the process is to implement an attestation trust score so the underlying carrier can verify the calls and SMS outbound traffic from companies is not spam, robocalls, or fraudulent.

Which regions are impacted by these regulatory changes?

These changes only impact US customers for now, but we expect other regions to follow suit in the future. That being said, if you are outside the United States and have purchased a US phone number number you will need to register that number.

If I am using CallTrackingMetrics for attribution only, do these regulatory changes pertain to me?

If you are using call queues to route your inbound calls to a receiving number, you will need to register. If you are only forwarding inbound calls from a tracking number to a receiving number, you technically do not need to register that number. Please note this is subject to change in the future.

Once I register my business, how long does it take to get an Attestation Trust Score?

Normally the Attestation Trust Scores will be delivered within a week.

What dependencies reflect my Attestation Trust Score provided by the carrier?

Business attestation scoring is based on Business Type, longevity, address, Tax ID or DUNS number. Note: the longer a company is in business and once registered the score could go up according to the carriers.

Are there costs involved with registering my account to obtain an attestation score when I’m signing up for service or if I’m an existing customer?

No fee is involved for initial registration of your business profile.

Can I challenge the Assestation Trust Score?

Yes, by paying a fee to a 3rd party verification provider they can do an independent check and provide you a Trust Score. The fee normally runs anywhere from $40.00 to $55.00.

Once I’ve been provided an attestation trust score is there anything else I need to do?

Yes, You will need to register the phone number for both STIR/SHAKEN and if you are using A2P messaging you will need to add your Brand, campaign type, and a sample message which will be submitted to the carrier for approval.

What can I do to avoid rejection of my business registration?

When registering your business for STIR/SHAKEN, we recommend you use the information included on your W9. You should enter the exact information as it appears on your W9 form including the legal business name (as spelled on the W9, including capitalization and punctuation), the business address (as spelled on the W9, including capitalization, punctuation, suite number, etc.), and all other information that is on the W9 that is needed for the registration form.

 

We also have seen more successful registrations when you use your EIN (Tax ID).  A tool to use for EIN verification can be found here:  https://www.hipaaspace.com/ein/ein_verification/

What do I do if there is an error with my submission?

You are now able to edit existing submissions. You can also create a new compliance using the “Add Compliance” button in the upper right hand corner of the Trust Center, and resubmit.

If I am an agency, will I need to register all of my sub accounts individually?

The new regulation for A2P and STIR/SHAKEN will require you submit this information for each business or sub-account within your CallTrackingMetrics account. CallTrackingMetrics is working to streamline this process for our agency customers and will share additional information as it becomes available.

I have sub-accounts for different departments and virtual teams within my internal organization. Can these sub-accounts be registered under one company name?

Yes, they can be under one company name under Declared Use Case. Please note, any text message sent from CallTrackingMetrics is considered an A2P message

STIR/SHAKEN FAQs

Where does the term SHAKEN come from?

SHAKEN is an acronym standing for Signature-based Handling of Asserted information using toKENs. SHAKEN is a software based verification process designed to significantly reduce robocalls as well as ensuring caller ID displays are valid protecting consumers. The FCC’s recent report states that unwanted calls are their number one consumer complaint. Caller ID spoofing leads to fraud.

Did an industry group create SHAKEN?

Yes, SHAKEN was created by the task force IP-NNI working for ATIS-SIP Forum. IP-NNI stands for “Internet Protocol – Network to Network Interface”. The Internet Engineering Task Force (IETF) formed the working group STIR (Secure Telephone Identity Revisited) to develop policies for carriers. STIR in turn created SHAKEN which is why it is typically referred to as STIR/SHAKEN.

How does SHAKEN work?

Based on a business profile created by the company there are multiple factors that drive an attestation trust score. Trust scores are derived from the longevity of the business, tax ID or DUNS number, physical address, and verified company contacts. Based on the attestation trust score, calls that are being initiated by a company and delivered to the carrier’s consumer phone, validation will be provided in the following (e.g. Spam, Scam Likely, or “valid company name” ).

When does STIR/SHAKEN go into effect?

Beginning June 30, 2021 STIR-SHAKEN initiative will be implemented by United States telecommunications providers. This will enhance consumer confidence and trust when accepting calls.

What will my caller ID look like when STIR/SHAKEN is implemented on my phone.

That will depend on your provider, and telephone manufacturer as to what caller ID display will show (e.g. Spam, Scam Likely, or “valid company name” ).

Will STIR/SHAKEN cost me additional fees?

At this time, CallTrackingMetrics is not aware of any additional fees to consumers. However, the industry is still defining guidelines. Agencies may incur fees when challenging their attestation trust score.

I receive many calls from international companies and their representatives utilizing ten digit United States telephone numbers. Will STIR/SHAKEN benefit me?

Yes, the business attestation trust score generated from these calls will be vetted to ensure validity of the company’s identity.

What will happen to calls that receive low attestation scores? Will carriers deliver such calls?

At this time carriers are still defining rules and attestation criteria. There is no clear plan for calls with low attestation scores. However, it is possible that low attestation scored calls will not be delivered. As information becomes available we will post updates here.

How does a business maintain a high attestation score?

Once an attestation trust score is established, over time businesses will gain additional credibility and their attestation score should increase with the carriers. However, low answers rates and short call duration calls (Under 60 seconds) could contribute to lowering a company’s attestation trust score causing calls not to be delivered.

If I make a STIR/SHAKEN-signed call that potentially is a robocall will the underlying carrier deliver the call?

Yes, if you have established a high attestation trust score the call should be delivered. The higher the attestation score, the more likely the call will be delivered to the end user. Should a company’s attestation score drop, they will most likely see a decline in call delivery.

A2P FAQs

How does A2P 10DLC work?

The requirements needed for the A2P 10DLC service are as follows:

  • Business profile creation/registration is the first step needed to identify who they are in order to send messages to the carrier networks.
  • Businesses will then need to register their Band and the campaign type and provide a sample message (or two) that they are sending to their customers e.g. campaign types, marketing messages, account notifications, delivery notifications, etc.
  • Registration will need to be completed using the CTM A2P 10DLC registration page for all types of messages being sent.
What is the timeline for registration and deadlines for A2P 10DLC registration?

At this time, no information has been confirmed by the carriers regarding an official timeline. We will share additional information and deadlines as they become available.

What happens if I don't register?

We encourage customers that are currently sending messages to complete the registration process so your messages are delivered. Carriers will begin assessing pass through surcharges for unregistered traffic for SMS and MMS (see the fees table below). Carriers also intend to increase their filtering for non-registered SMS and MMS, to protect their customers from unwanted messages or SPAM.

Once CTM gets further information regarding this we will update this document accordingly.

How does Brand registration work?

After you complete your A2P 10DLC Profile and register your campaigns Brand and a sample message (or Two) you will be provided a Trust Score of: High, Medium, or Low trust. Based on these Trust scores will determine the message throughput rate that the carrier provides you. So the higher the trust score the more messages you can send over the carriers network.

So what does a Trust Score truly mean and how is it determined?

Once you complete the registration process of your Business Profile and register your Brand for A2P 10DLC campaign messaging the information it will be sent to a 3rd party at the center of this new registration system, also known as The Campaign Registry (TRC). TCR will use a reputation algorithm to review specific information about your company, and will assign a “Trust Score” that will determine your messaging throughput rate.

Why does the Trust Score determine my throughput rate?

Since Trust Scores have three different levels (Low, Medium, to High) the score will be used along with your Campaign type to determine the total throughput rate for the Campaign type you wish to send.

What’s a Campaign?

A series of use cases make up a campaign type. Each use case represents the type of notification you would like to provide. So for example, if you would like to run a marketing campaign for coupon advertisements, that would fall under a marketing use case, or you wanted to send out appointment reminders to your customer, that would fall under the category of Reminders, A list of detail use cases are provided below. One note: each campaign (or Use Case) type needs to be registered.

Do I need to select a Use Case when registering a campaign?

Yes, the use case determines the type of message being sent and determines the carrier passthrough fee that will be charged for each message on AT&T network.

Use cases vary from reminders, 2 factor authentication, marketing messages, customer notifications, to public service announcements, and many more. A list is provided below for the Use Cases.

Do peer-to-peer text fall under the use case for Conversational Messaging? If so, should this type of conversation also be pre-registered as a campaign?

Yes, you will want to register this as Conversation Messaging which is a Declared Use Case. Any text message sent from Calltrackingmetrics is considered an A2P message.

With these changes will I need to register my campaign in the The Campaign Registry?

No, registration will be available entirely through CallTrackingMetrics. CallTrackingMetrics and our partners have integrated directly with The Campaign Registry (TCR) to facilitate registration for customers.

Will I need new phone numbers to use this A2P 10DLC service?

No, if you already are using 10 digit phone numbers for sending messages there is no need to buy new numbers. However, you will need to register the existing phone numbers for each campaign type to ensure your message will be delivered.

If I would like to register for the A2P 10 DLC brand, what is needed?

In order to register your business profile, brands, and campaigns, you will need to have information about each business and brand. The required information may include the business name, physical address, business type, Industry type, Tax ID or DUNS number, and provide 1 company contact under your business profile.

Once I submit my Brand and Campaign registration, how do I assign phone numbers for my A2P 10DLC campaign?

Once your Brand(s) and Campaign(s) are approved, you will need to link each of your A2P Campaigns to the phone numbers you would like to use for that campaign. Any numbers that you add to that campaign will be automatically associated with the Campaign that you assigned to that messaging service.

What about MMS messaging are they affected by A2P 10DLC change?

Yes, it is recommended that if you are using high-volume MMS campaigns, then leveraging a short code is still the best option.

Are dedicated Short codes or Toll Free Numbers affected by these A2P 10DLC changes?

These changes do not directly affect dedicated short codes along with Toll-Free numbers.

Carrier Fees FAQs

What fees are associated with the A2P 10DLC service?

There are fees for both sending A2P 10DLC messages along with campaign registration.

Brand registration fee: $4 one-time registration fee, per Brand.

Telephone Consumer Protection Act (TCPA) FAQs

What is TCPA?

TCPA, or the Telephone Consumer Protection Act are rules and regulations put in place by the The Federal Communications Commission that went into effect in 1992.

How does STIR/SHAKEN tie into TCPA?

STIR/SHAKEN is an expansion of TCPA, and is being put in place to instill calling confidence with customers. This set of industry standards is designed to reduce spam robocalls, prevent the “spoofing” of Caller ID data and help businesses improve voice security

What is considered a robocall?

Robocalls are prerecorded or autodialed calls made to your landline or cell phone, usually when you have not given permission for the caller to contact you. They are often made by telemarketers, who are callers contacting you to sell a product or service, usually unsolicited. Robocalls can also come from other entities besides telemarketers, such as debt collectors.

What are the specific TCPA rules for telemarketing?
  • Telemarketing calls can only be made between the hours of 8 a.m. and 9 p.m. (local time at the called party’s location)
  • All telemarketers must comply with limits on “abandoned calls” and employ other consumer-friendly practices when using automated telephone-dialing equipment
  • A telemarketer must abandon no more than 3 percent of calls answered by a person and must deliver a prerecorded identification message when abandoning a call
  • Telemarketers must not disconnect an unanswered telemarketing call prior to at least 15 seconds or four rings
  • All pre-recorded messages, whether delivered by automated dialing equipment or not, must identify the name of the entity responsible for initiating the call, along with the telephone number of that entity that can be used during normal business hours to ask not to be called again
  • All telemarketers must transmit caller ID information, when available, and must refrain from blocking any such transmission(s) to the consumer
  • All businesses that use auto dialers to sell services must maintain records documenting compliance with call abandonment rules
  • Make sure to provide an opt-out function to put the phone number on the DNC registry
  • The (Do Not Call Registry) DNC list needs to be specific to your organization and on file for 5 years
  • Avoid calling numbers where the recipient is paying for the call (healthcare offices, mobile numbers, and even medical facilities)
Where can I find the National Do Not Call registry?

This is the page the FCC maintains regarding how businesses can sign up to get subscriptions for the FCC’s do not call lists. Businesses can purchase subscriptions for specific area codes or for all area codes. (See Subscribing To Area Codes section)

Campaign registration fees

Campaign Type

Cost

Regular Campaign
$10/month
Low-volume* Mixed-use Campaign
$2/month
Charity Campaigns
$5/month
* The threshold for "low volume" has not yet been defined by carriers. This article will be updated when that information is available.

AT&T Surcharge Passthrough Fees

Campaign Type

AT&T long code SMS carrier fee (per segment)

AT&T long code MMS carrier fee

Use cases within campaign type

Declared Use Case
$0.002
$0.0035
Single use case covering 2FA, authentication, customer care, group messaging, notifications, operations, and anything else indicated "Declared" in Table 2 below.
Mixed / Marketing Use Case
$0.003
$0.0035
Marketing use case or combination of use cases under one campaign.
Basic / Unregistered
$0.002-$0.004
$0.0035-$0.005
High risk provider or unregistered traffic
Transition Period
$0.002
$0.0035
Special (select use cases only)
$0.000
$0.000
Charity, emergency services, public safety

Use Cases

Use Case

Campaign Type

Add'l carrier vetting required?

Description

2FA
Declared
No
Any authentication or account verification such as OTP
Account Notifications
Declared
No
Notifications about the status of an account or related to being a part of an account
Customer Care
Declared
No
Support, account management, and other avenues of customer interaction
Delivery Notifications
Declared
No
Information about the status of a delivery
Fraud Alert Messaging
Declared
No
Messaging about potential fraudulent activity such as spending alerts
Higher Education
Declared
No
Message campaigns from colleges, universities, and other education institutions
Low Volume Mixed
Mixed/Marketing
No
A campaign that covers multiple use cases such as marketing promotions and delivery notifications. Primarily for small businesses. Note - mixed campaigns are likely to have lower throughput and a higher cost per message.
Marketing
Mixed/Marketing
No
Promotional content such as sales and limited time offers
Mixed
Mixed/Marketing
No
A campaign that covers multiple use cases such as Customer Care and Delivery Notifications. Note - mixed campaigns are likely to have lower throughput and a higher cost per message.
Polling and voting
Declared
No
Notifications about polling and voting
Public Service Announcement
Declared
No
PSAs to raise audience awareness about a given topic
Security Alert
Declared
No
Notification of a compromised system (software or hardware related)
Carrier Exemptions
Special
Yes
Carrier-exempted campaigns
Charity
Special
Yes
Messages from a registered charity such as 501c3 charities. Note - religious organizations are not included
Conversational Messaging
Declared
Yes
In-app peer-to-peer (P2P) conversations using proxied or pooled numbers or personalized services for enterprise or A2P communications to protect privacy of personal numbers
Emergency
Special
Yes
Notifications about/supporting public safety during emergency situations
Sweepstakes
Special
Yes
Sweepstakes related communications
Political
Declared
Yes
Messages from a verified campaign to influence decision making
Social
Declared
Yes
Non-commercial communication within or between closed communities

Contact Support

I have some additional questions. Who do I contact?

There are several ways to contact our support team. If you are inside the CallTrackingMetrics platform, you may select the “Chat with Support” option. Additionally, you may reach our team by phone at (443) 432-2896 or create a support ticket by sending an email to info@calltrackingmetrics.com.

To help keep customers informed, we are sending regular emails related to these regulatory changes and proactively keeping this web page up-to-date. We recommend reviewing these resources often, as information is subject to change.

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