TCR (The Campaign Registry, US) Filing to the FCC, Feb 7th 2024

In reviewing FCC filings, TCR made one on February 7, 2024;  after it met with the FCC on February 5, 2024. https://www.fcc.gov/ecfs/document/10207829015272/1.

The quote below from the document is the most relevant and critically confirms what we’ve been saying since last year about TCR and its inability to stop SMS spam. Today while all carrier networks are struggling to deliver mobile service, I received an SMS SPAM from “Kayla offering to buy my home.”

We noted that TCR’s objective, in conjunction with its carrier partners and campaign service provider customers, is to advance the Commission’s interest in protecting consumers from illegal and unwanted text messages. We also clarified TCR’s role in the messaging ecosystem, explaining that the company collects and validates information regarding campaign service providers’ customers and their messaging campaigns, but does not, and is not able to, view the content of, filter, or block messages sent by campaign service providers’ customers to mobile subscribers.

TCR Filing made on Feb 7th 2024 to the FCC, https://www.fcc.gov/ecfs/document/10207829015272/1

Understanding the TCR

Last year we discovered TCR does not have any 10DLC numbers, https://alanquayle.com/2023/08/understanding-tcr-and-kaleyra/. TCR simply validates campaign information without adequate validation of the business entity submitting it. The identity used is given by the applicant (potential spammer). TCR relies on other parties NetNumber and the Campaign Service Provider / Direct Carrier Aggregator to check TCR’s campaign approval and do their part in sending SMS. If you’ve ever played the children’s game ‘Chinese Whispers’ or ‘Telephone’ you’ll understand the inefficiency of this process to stop SPAM. A spammer’s campaign need only run for minutes to a few hours to make money.

The above statement to the FCC also contrasts to what TCR wrote in reply to the FCC’s Targeting and Eliminating Unlawful Text Messages, CG Docket No. 21-402  We highlighted some of the statements at issue in the post, “Was the FCC Lied to? What the FCC was told on SMS spam”. https://alanquayle.com/2024/01/was-the-fcc-lied-to/. 

What the TCR said in 2022, “enable our stakeholders to track messaging back to its origins so that they can conduct the necessary follow up for the messaging in question”. No phone number is recorded by the TCR. It requires the CSP (Campaign Service Provider) to record that, and for the campaign to not be cycling through phone numbers, which a spammer will likely do.

What the TCR said in 2022, “giving Brands an opportunity to prove they are sending CTIA compliant messaging.” The above TCR filing clearly states, “does not, and is not able to, view the content of, filter, or block messages sent by campaign service providers’ customers to mobile subscribers.” A form is completed that says how the campaign will behave. But brands have been mimicked by spammers, and brands have been hacked by spammers.

The TCR said in 2022, “While the current process may appear to be reactive, the reality is that MNOs, DCAs and CSPs are quickly making improvements around messaging from the data they are aggregating to/from TCR.” It’s 2024 and the barn door remains wide open, the ecosystem has not moved quickly to stop SMS spam.

So What?

It is good TCR has come clean on the limits of their platform. They essentially have responsibility to stop spam but lack control. They rubber stamp some paperwork, and let others do their work in delivering SMS. Our everyday experience of SMS spam continues to show the Messaging Monopolies failure to address the one thing all mobile customers care about, stopping spam.

While the Messaging Monopolies and Carriers are able to charge 0.5-1c per 10DLC A2P message. Amongst many other fees and fines, covered in the Telecom Triopoly post, see below. The thing that works is charging businesses, not stopping SPAM.

But it’s worse than this, by admitting TCR doesn’t know or track the phone numbers means the current structure will prevent enforcement actions against spammers. Consider this scenario, a spammer uses a campaign to get their spam through, and then changes the numbers in the NetNumber database. No one will be able to trace the spam back to a campaign. The whole system now enables spam to remain untraceable, spam is OK as long as they pay A2P termination fees.

Identity is the crux of the spam problem, identity of the brand and identity of the mobile customer. Self Sovereign Identity is built to solve the problem every mobile customer faces in spam and unwanted messages. To learn more check out “Podcast 29: TADSummit Innovators, Noah Rafalko, TNID”; and “Podcast 27: Truth in Telecoms, Taking Back Control & Save Grandma – The Fight Against SMS Spam and Robocalls!”

Relevant Previous Posts

Was the FCC Lied to? What the FCC was told on SMS spam.

The Telecom Triopoly

Original Messaging Monopolies Post – assumes a fair bit of industry knowledge

Messaging Monopolies Simplified

Major William Peters, Plaintiff, versus Kaleyra, Defendant.

Understanding TCR and Kaleyra Part 2

Understanding TCR and Kaleyra Part 1

The Campaign Registry and Foreign Ownership: A Matter of National Security