Hi Rich, thanks so much for your comments, this is exactly what we want, open discussion. Starting with your first comment:

Rich Eicher: “The Campaign Registry alone decides whether a political campaign’s text message is appropriate to send to your mobile phone.” – FALSE!”

As far as I am aware there are no other options to text enable your existing corporate or small business telephone lines without going through this process, which I’ve verified with CSPs, brands, and others in our industry.

1- Before you can send SMS to your customers who previously consented, you are required to submit sensitive corporate, customer contacts & use case data. Brands and CSPs have told me there are 30+ fields of data required. This data is vetted and scored with an exclusive brand registration partner Aegis Mobile, the charge being the initial vet fee.

2- If you get a low vet score that can not support your existing campaigns, you can pay a larger fee to potentially be granted a higher score from Aegis Mobile (99% of market) or WMC Global (1%).

3- The next step is choosing from one of the many connectivity partners who pay to have access to sending “registered” messages.

4- Once you finish paying the TCR and Aegis up-front fees, the second wave of fees will come on separate companies’ bills. Net Number is one of them. No matter what type of message, if it is used by a business, a campaign and A2P flag must be added. There is an issue pointed out by several people publicly, if someone was a spammer, couldn’t they load any telephone numbers or rotate them out if they were blocked?

5- By now we have entered the data into four different companies’ databases. All of these companies are monopolies, charge fee(s), and have the ability to impede a campaign. What protections and reporting exist if a bad actor from any of these monopolies impacts a campaign?

A campaign can be canceled because “Carrier X told us to.” Where is the appeals process? See later question on why this is an important issue.

You are saying TCR has no role besides storing information? While they appear as the gatekeeper for approvals with the carriers. Brand and CSPs back me up on this assertion.

I have a few questions:

• Please explain the appeals process for a brand, is it documented?
• How many companies get “special pricing” for campaigns or are able to pre-pay for a discount? Are any of these offers available to the rest of the stakeholders?
• Why did one carrier demand higher security guarantees beyond FCC / CTIA guidelines and are these made publicly available to the rest of the stakeholders to avoid problems with their campaigns?
• TCR went live in Aug 2020, it’s been 3 years and we’re still receiving billions of SMS spam per month. Other developed countries seem to have a better handle on SMS spam without all these monopolies, that’s going on? Being frank there seem to be too many chefs in the kitchen, and they all seem to be positioned as fall guys to avoid carriers taking any responsibility for this situation.

My objectives here are simple: shine a light on the SMS spam problem affecting most Americans that appears better solved in other developed countries; an ecosystem that appears to be making SMS less attractive for brands (business cases are getting really tough for SMS) and consumers (being told not to click on URLs in SMS); and worryingly the programmable communications industry is being squeezed out of existence – there will be some bankruptcies and highly discounted M&A soon. Innovation is being stifled in the largest programmable telecoms / communication market.