Responding to several reader requests, this post is a simplified version of the original Messaging Monopolies, with more background explanations, a few analogies, and less assumptions made on the readers’ detailed knowledge of the US SMS industry. It is longer, but I hope makes things a little clearer.
In the Appendix we walk through a simplified process a brand goes through to register with TCR and then send a 10DLC (10 Digit Long Code, regular phone number) campaign. The basic entities covered in this post are shown below.
The Campaign Registry (TCR), now owned by Tata Communications, is the exclusive partner of the US Mobile operators for “sanctioned” text messaging. The word “sanctioned” means carrier approved. Even though the carriers remain at arm’s length from the companies discussed in this post, the carriers are like the Gods on Mount Olympus of the Messaging Monopolies. They direct the actions of the Messaging Monopolies, though not publicly.
Before TCR, unregistered SMS were considered conversational or what is referred to as P2P (Person to Person) texting and the charges were around $.00001 per outbound SMS. Today registered 10DLC SMS are charged at $0.005, A2P is now five hundred times more expensive in the US. Unregistered SMS should no longer be sent, however, there was a stated charge of $.01 per unregistered 10DLC SMS.
According to Robokiller’s report from August 2023 there were 238.4B delivered spam texts in the US during the trailing 12 months, which works out to 722 spam SMS for every person in the US. Any message that is not registered with the TCR is considered spam and should not be sent. However, Robokillers’ numbers for September and October 2023 remain at similar volumes, around 230M according to Robokiller. Unregistered SMS should not be sent today, however, it’s clear billions of unregistered SMS are being sent.
Assuming 1c per unregistered SMS, that’s roughly $2.4B per year of additional revenue and profit to the US carriers. That’s a significant incentive to NOT stop spam. Carriers or possibly DCAs (Direct Carrier Access), a text messaging provider having direct connections/agreements with operator(s), are also removing some spam texts over their networks, for which those texts are also paid, hence the SMS spam numbers and revenue earned could be even higher than these estimates.
US Consumers are not being protected
An argument raised with Robokillers’ numbers is that they also include unwanted SMS. Given customers are advised not to respond to unwanted texts, as that may result in more spam, to claim there is a difference between unwanted texts and spam is false. Simply, unwanted SMS is spam, like unwanted emails are spam, it’s the customer that defines spam not the network. Gmail provides a good template on how to manage the spam problem.
The do not call list is another example of ineffective consumer protection, today we simply ignore calls from numbers we do not recognize. The rules protecting consumers from robocalling, TCPA (The Consumer protection Act), were extended to SMS though in practice it appears over 100M robocalls are required for action by the FCC. Even if fines are imposed, recovery of fines continues to be rare.
The American public are not being protected, we experience this every day with spam SMS and robocalls. There are numerous groups that answer robocalls and spam SMS. For example, the elderly who grew up answering the phone and responding to SMS, or those waiting on important calls that are unable to ignore their phone. Our children are also being exposed to robocalls and spam SMS on a daily basis. Other countries have solved the spam problem, the US telecoms industry is simply not protecting Americans. Perhaps the phenomena of Switfies can be brought to bear on the problem, and force action?
It’s getting really complicated for brands
SMS are also being blocked beyond the TCR. As evidence for this, some businesses are seeing non delivery of approved SMS depending on the receiver’s carrier. In one case an established campaign for a medical conference added the name of the evening’s headline act, a grammy award winner, and some messages were not delivered. They never resolved that problem, just avoided mentioning the grammy award winner in future texts. The ‘censorship’ rules are not clear, brands and CSPs continue to learn everyday what may be blocked in an approved campaign depending on the DCA and carrier used.
There are many issues with the current TCR solution. For example, a DCA can link a specific campaign to a phone number, and a partisan actor within that DCA can raise complaints of spam for that number, potentially closing down a campaign without the brand campaign owner’s knowledge.
One of the issues in registering campaigns is if a brand is required by law, contract, or security policy not to provide customer identifying data to a third party, namely the TCR. This is potentially in direct violation HIPAA (Health Insurance Portability and Accountability Act), PII (Personal Identifiable Information), and CPNI (Customer Proprietary Network Information) where federal regulations are broken when the voice provider text enables the same number for their client and is required to provide protected customer data. A simpler approach to this complex problem would be to confirm the identity of the sender, but that is for another post.
For shortcode SMS and 800SMS there are additional messaging monopolies, but for the sake of simplicity we focus on 10DLC.
Aegis Mobile and its TCR Vetting Monopoly
TCR effectively uses a single source, Aegis Mobile, for initial “vetting” of a brand into TCR. A brand is any business, any size, profit or non profit, free or paid, conversational, religious, or political. TCR “requires” registration of highly sensitive information, such as:
- Name of contact
- Company Legal Name
- DBA-if different
- Legal Org Type
- Country of registration
- Tax ID or Foreign tax id code
- Address, city etc.
- Website or online presence
- Stock Symbol
- Industry Type, which is limited to 23 industry categories. A concern for many businesses in industries not exactly covered, is does a poor fit impact their vetting score?
If the business is a sole proprietor the information required:
- Reference ID: a unique identifier that isn’t clearly defined. An internal account number.
- Contact: first name last, name
- Telephone number and mobile number
- SSN, social security number.
- The CSP is required to provide in-depth monthly reporting for sole proprietors. If one sole prop sends the wrong type of message, all sole prop for that CSP could be placed in jeopardy of being shut off.
The fees for vetting are:
- Brand application fee: $4, one-time.
- If you don’t like the score you can do a “Standard” vet for $40, which may increase your score.
- Enhanced third-party brand vetting fee: $95, one-time. It’s optional, as it’s only required if you plan to send more than 2000 SMS per day.
- Failed standard vetting fee: $5,
- If you want to appeal the vet based on incorrect or provide additional information (BTW not described what that actually is) submitted beyond 45 days.
- Political vetting fee: $65 for standard USPS delivery of a PIN, or $91.95 for express USPS delivery of a PIN.
- Failed Political Vet is charged $22.
Initial vetting is the first time a brand is reviewed by Aegis Mobile. An initial vet can result in a low rating, and subsequent vetting must be paid for to raise the score by providing additional information and/or completing the form in a certain way that will likely result in a better rating. There is a significant human component to this process, and the CSP’s have built expertise in navigating this process and how best to complete the forms. Though with all monopolies, inside contacts at these entities can provide a special process.
The often confidential information provided as part of the vetting process is shared not only with Aegis but also between other domestic and potentially foreign parties without concern of typically required security protocols to house this data. Information provided to Aegis is not siloed away from TCR, nor from the carriers. The protections of a brand’s data, nor the process used to vet the brand are published.
Another issue is whether a CSP has agency for the brand and the authority to represent them through this process? After the brand is registered and vetted, it goes into the “double top secret” database that allegedly no one except the carriers can access. This point and the term used were made during interviews with people working with the messaging monopolies. The processes and security controls are not written down so the brands currently do not know what is happening to their data. The “double top secret” database potentially means a brand could never find out if someone else is sending spam in their name.
The TCR does not face oversight or regulation afforded to protect sensitive consumer and business data elsewhere. Considering the ever-increasing cyber attacks, TCR creates a highly attractive honey-pot of confidential data across US businesses wanting to use A2P SMS. Currently, every sole trader to the largest brands supporting text messaging in any form must comply with the TCR’s information request processes.
A Fictitious Vetting Example to Explain How it can be Unfair
Let’s review a real-world example using fictitious companies. Why does Home Depok Home Design Services (HDS) and Jenny’s Construction & Design Services (Jenny’s) both pay Aegis to be vetted? The fact that Jenny’s had been in business for 10 years and HDS was just formed and acquired a new Tax ID number didn’t factor in the vetting decision. HDS informed Aegis about the parent company Home Depok was identified as the parent organization to use the power of the larger brand to increase messaging capacity limits.
What if Jenny’s Construction had a nationwide customer base of 3m and had all opted-in to receive design tips, videos, and be able to purchase building designs in direct competition to HDS? What if Home Depok Home Design Services was losing market share due to Jenny’s tenacious marketing and ability to communicate in a way the customers wanted? That is until this monopoly returned a vetting “Score” which severely limited how many customers Jenny’s could update with a text. Enter HDS using the brand of it’s parent to compete and be provided the customer list that was not directly opted in by HDS but is now free game.
Aegis assigns the starting score based on an unknown and proprietary method that isn’t industry recognizable, measurable, or accountable. While potentially restricting small businesses from being able to compete with larger brands who “Score” higher and can send out text messages up to 1000x more often to crush perceived competition.
Clearly the process is broken as both Jenny’s and HDS are valid businesses, and should be allowed to send SMS at the rate they have paid. Customers can complain should HDS or Jenny’s send what the customer considers spam. I receive SMS from brands that I sign up for SMS alerts when waiting for notifications of my glasses arriving, and since then the messages go into my spam folder. I may change my settings should I buy glasses from them again, or search messages including spam, like I do with email.
Back to the Vetting Process
When the score returned by Aegis on a company is too low for the brand to meet the existing text communications needs, they can pay to re-do a basic vet, if for example the information was fat-fingered. The only hope is paying a higher vet fee of 10x the basic toll. This secondary, more costly “vet” process is another black box.
WMC Global is another option for a secondary vet; however, it appears they only account for less than 1% of vetting. TCR and Aegis Mobile worked on the same floor of an office building between June 2020 to Jan 2022, 5th Floor, 8605 Westwood Center Drive, Vienna, VA.
This black box vetting process could also impact political campaigns. For example, limiting text communications for an underfunded or grassroots political campaign, versus a political political campaign provider with billionaire donors.
There are so many questions the messaging monopoly raises:
- Well-established businesses are now forced to pay more to these messaging monopolies while being required to provide sensitive business information.
- How can a wireless operator levy anticompetitive fees and processes on a telephone number which is sent to their network and not pay when delivering a message back to the originating network? I know several brands that want such equity.
- How can this situation be allowed by elected officials to allow a handful of monopolies to control, restrict, and censor a critical national communications infrastructure?
- How can a mobile operator receive a text message from a landline, charge a delivery fee and refuse to deliver a return message if requested to provide a fair reciprocal cost in return? As is the case for P2P mobile messaging.
- Why does the same message sent from a businesses’ text enabled voice lines they have been using for decades, now incur scoring / vetting, and invasive data requests? The UCaaS / CCaaS providers are also suffering this fate.
- Why is the same business able to use their wireless telephone service without registering their business, use case, include stop/help/quit in every message and pay nothing in addition to their mobile phone plan cost?
- Why can campaigns send messages via Whatsapp, Line, Telegram, iMessage, and all other IP-based messaging services that use the same wireless networks and not be charged for every message, forced to register exposing sensitive customer data, and potentially improperly blocked / limited? We are starting to see brands voting with their feet, particularly in the 2FA use case in the move away from SMS and back to email and towards passkeys.
Net Number Monopoly
The telecom ecosystem in North America is complex. MNOs (AT&T, Verizon, and T-Mobile account for most mobile customers) and MVNOs offer mobile services to their customers. Many telecom providers and cable companies offer landline numbers. The landline numbers can be enabled for texting, which is a convenient service for businesses who want to better connect with their customers. In addition, a vast number of innovative VoIP services have gained popularity and complement the suite of communication services available. This choice is great for consumers but complex when message routing needs to be set up.
The Netnumber Services Registry (nnSR) is an industry database that manages and distributes authoritative routing information for the messaging industry, helping messaging services by publishing dedicated service information for individual phone numbers. Communication Service Providers provision telephone numbers into the nnSR and associate them with NNIDs (netnumber ID isa 6-digit routing number that uniquely identifies each service provider in the world) and A2P campaign information. The messaging ecosystem consumes the respective data as regular updates or real-time queries. The result is a solution that can support use cases across network mergers and migrations, MVNO networks, SMS or MMS enablement and 10DLC A2P campaigns.
The field called “Alt-SPID” (alternative service provider ID) was used for identifying a text enabled number within a sanctioned industry administrative database NPAC-Number Portability Administration Center database, run by iConectiv. When Net Number aligned with the other messaging monopolies, this free field was intentionally ignored by carriers when the TCR was launched. Net Number’s database is now anointed as the required place you must load the telephone number to be recognized as text enabled. This is a requirement to attach a campaign ID from the TCR or the texting will be shut down or will be considered spam. It’s an example of how these monopolies sneakily come into existence.
When loading a number into Netnumber as a customer that doesn’t have a Carrier License, but purchases the telephone number from a licensed non-wireless operator, requires a “Wet Ink” document called an SMS-LOA. This Letter of Authorization is required by Net Number to be signed by the licensed operator in which the OCN is assigned to by the government.
Here is the process to set up an OCN, it’s not for the faint-hearted. OCN-Company Codes, also referred to as Operating Company Numbers (OCNs) are used like social security numbers to uniquely identify your company and are assigned to all telecommunications service providers. They are used throughout the industry to facilitate the exchange of information.
Net Number is not a government assigned number administrator. That means they are not recognized, governed, nor overseen by any regulatory authority. Unlike all of the telephone numbers shared and managed today between government appointed number management administrators, carriers, and customers. Net Number has a monopoly that is driven solely by its commercial interests that are not in the public’s best interest. This leads to hamstrung innovation, lack of oversight, potential for data breaches, and an anticompetitive ecosystem.
If you are a licensed traditional operator providing telephone numbers and are being held accountable via government regulations to a defined and regulated privacy standard, it is galling to see rogue monopolies allowed to sidestep and monetize.
Syniverse was established in 1987, providing voice and messaging clearing, settlement and exchange services. Enabling telcos large and small to interconnect. They provide many services to carriers beyond voice and messaging. Our focus here is North American messaging.
Syniverse is one of the only two companies fully connected to all three major mobile networks. The term used for such a company is DCA-Direct Carrier Aggregator. Sinch is the other DCA. However, for A2P SMS Syniverse is the only one that connects with all 3 main carriers. Sinch connects to Verizon for P2P messaging, and interconnects with Syniverse for A2P under a peering agreement.
Syniverse also charges a $15 campaign vetting fee per campaign, if the campaign is resubmitted because it was rejected or other restrictions stopped the campaign meeting the brands needs, another $15 charge applies. Sinch does not make such a charge, but as they interconnect through Syniverse for A2P there is likely some deal in place. Also Syniverse interconnects with the carriers with zero charge. One possibility is the $750M investment Twilio made in Syniverse gives it access to this special type of interconnect.
There is a significant switching cost between DCAs. Note when I state Syniverse, for example:
- You started with Sinch (the only other fully direct DCA)
- Sinch approves your campaign (I’m assuming with zero review fee as they have not yet stated a charge).
- You decide you don’t like Sinch and want to move your texting to the other exclusive DCA, Syniverse.
- Let’s say you support 10,000 businesses/Brands that went through this process and are up and running with little to zero complaints from end customers.
- Assuming each brand has 2 campaigns, some brands have many more.
- That will cost you or your clients $300,000 USD, just to move your service.
- The other issue is it can take approximately 10-12 business days to have each already running campaign reviewed again. 10k campaigns could take weeks to be reviewed.
- If you already work with Syniverse, and a prospect uses another aggregator that uses Syniverse, they will charge you even if the campaigns have been approved by Syniverse. This essentially forces brands to work directly with Syniverse or Sinch, limiting competition.
Some Final Questions
If you consider the above statements false and / or misleading:
- Where else can you register a text messaging campaign for A2P outside of TCR?
- Where outside of TCR can you run A2P traffic without having to register at all?
- Where can you ‘vet’ a brand initially outside of Aegis Mobile?
- Where can you load a number to be text enabled outside of Net Number?
- How can you migrate between texting companies without a potentially large financial impact or even a risk of not being re-approved for the prior approved campaign?
Calling all Swifties to save us all!
Competition in programmable communications is being stifled by a growing number of monopolies, this is perverse. Urgent action is required, the bottom line is SMS spam is not being stopped and its earning #SMSspam Club $2.4B per year.
Go review your wireless bills today and look for “Call Filtering”, “Economic Adjustment Fee”, Call and or robo-call service fees.” most hover around $5-$10 per line, per month.
I read that if you add all the fluff fees up at an average of $5-10 per telephone number per month across the approx 300m subscribers in the USA that totals $1.5b-$3B per month.
Gathering all the information for this post was very difficult. Most brands, enterprises, UCaaS, CPaaS and CCaaS providers have limited knowledge on all the monopolies that exist, even many of the SMS aggregators do not have the span of knowledge in this post.
I’ve published the TCR Trilogy, and through the Truth In Telecoms segment of the TADSummit podcast we’ve started to discuss a few of these issues facing innovators. It’s time for the industry to start commenting, discussing, and expressing your views on what is going on.
If I’m wrong, let me know. If you agree, express your support for what is being uncovered here. Change is urgently required. The book-clubs have shown they’re not going to change the situation, only support the messaging monopolies through low-ball questions, if questioned at all. The bottom line is mobile customers continue to suffer, and innovation is being stifled.
Perhaps the phenomena of Switfies can be brought to bear on the problem, and force action to protect all Americans.
Check out other articles in this series:
Original Messaging Monopolies Post – assumes a fair bit of industry knowledge
Appendix. Example of How the Messaging Monopolies Work Together
A brand that could have been operating A2P campaigns for years is treated the same as a first time A2P user brand. There is no retained history in this ecosystem.
Step 1, Set Up Brand Account and Enter Required Information
The first set requires a brand to set up an account with the TCR, or have a CSP (which could be a DCA) set up a brand account on their behalf. This normally can be completed within one day, its form completion.
Step 2, Vetting information passed to Aegis Mobile and Vetting Score Returned
This step can be iterative if the score is low, also this process has a number of options, standard / enhanced vetting, and political campaign vetting. This can take a few days to a few weeks.
Step 3, TCR notifies Brand or CSP agent of decision
Once the TCR makes a decision the brand and CSP agent are notified. The CSP can use its experience to advise on whether the TCR decision will enable the brand to operate the campaign at the required performance, which the brand may have been running satisfactorily for years.
Step 4, CSP updates nnSR with the Campaign ID for the brand’s numbers
The CSP or DCA acting as a CSP sends to the Netnumber service registry the campaign IDs for the mobile numbers used by the brand. This is normally performed within one working day.
Step 5, Brand sends Campaign SMS to preferred CSP, DCA checks number has approval for Campaign and passes onto Carrier.
The brand sends its campaign SMS to its preferred aggregator / CSP, which checks with the nnSR, and then forwards it on to its preferred DCA. DCA may perform a nnSR check. Sinch forwards to Syniverse under its A2P peering agreement, Syniverse forwards all A2P SMS onto the carriers. Carriers may perform additional checks, and finally deliver the A2P SMS to the mobile subscriber.