If your business owns a toll-free phone number, you can text enable it immediately and begin sending and receiving texts from your customers quickly, easily and for very little cost. But on June 7, 2018, the Federal Communications Commission (FCC) proposed a rule that would make it more difficult for you to do that. This rule would require toll-free subscribers to inform voice services agents called RespOrgs before they are able to text enable a toll-free line. The stated intent of the ruling is to prevent fraud, but in reality, it does not add any additional fraud protection and unnecessarily complicates your ability to text enable your toll-free phone numbers. Plus, the proposed rule would require subscribers to pay an additional fee to the RespOrgs, increasing the cost of toll-free business texting.
The good news is that the rule is not yet official, and there is time to make your voice heard if you stand alongside Zipwhip in opposing the rule. Please go to https://www.fcc.gov/ecfs/filings/express, enter the proceeding number 18-28, fill out your contact information and type a brief comment in the box provided. The FCC is accepting public comments until September 7, 2018. If you’re not sure what to say in your comment, we encourage you to use the suggestions below.
Here are our answers to some common questions around what the FCC regulation means, why it’s bad for businesses and more information on the steps you can take now to help us fight it.
How does toll-free texting work?
Toll-free texting allows companies to facilitate two-way text conversations with customers. For businesses, text enabling toll-free numbers is a game changer. They no longer need to source different numbers for voice and text because their one toll-free number can do it all.
What safeguards are currently in place to protect against text message fraud?
Businesses currently text enable toll-free numbers by using a provider like Zipwhip to verify the legitimacy of their business number. We understand the importance of protecting the integrity of toll-free numbers, so we institute industry-leading safeguards to shield businesses and consumers from fraud.
Zipwhip’s multi-step verification process includes:
- A phone call with voice verification
- Online research indicating the business is tied to the same published phone number
- Confirmation that payment information is tied to the requesting business
Then, the business’s phone number is published to the industry de-facto database (NetNumber) indicating it has been text enabled.
How does the FCC want to change the toll-free texting process?
On June 7, 2018, the FCC voted to take comments on proposed rules that would alter the text enabling process. These rules would require toll-free subscribers to inform voice services agents called RespOrgs whenever they want to text enable a toll-free line.
Why did the FCC propose this ruling?
The FCC’s stated intent was to prevent fraud. However, the reality is that the ruling will not add any additional fraud protection. Zipwhip already collects authorization from you (the subscriber) to text enable your numbers. Our current safeguards already efficiently and effectively protect both businesses and consumers.
The proposed rule was influenced by Somos, a company that manages the toll-free voice registry for the telecommunications industry. Somos argues that there is a problem with surreptitious text enablement of numbers when in fact, there is not. If this ruling passes, Somos stands to gain tens of millions of dollars in monopolistic revenue as a direct result.
What would these FCC regulations mean for businesses?
If the proposal is adopted, it will take meaningfully longer to text enable a business phone line. Businesses will also face new reporting obligations and incur additional expenses in the form of fees paid to the RespOrgs. And if businesses fail to notify the RespOrg when they text enable their numbers, the FCC might impose fines or other penalties.
Currently, RespOrgs have no process for handling text-enablement requests. This means all requests will likely hit a dead end initially. As they try to navigate this new proposal, they will likely institute expensive fees to handle these requests – applying a major tax on the entire industry.
How can I oppose the FCC ruling and stop it from passing?
You can quickly and easily oppose this ruling by submitting a comment to the FCC here.
The proceeding number is 18-28. All you have to do is enter your contact information and type your brief comments in the box provided.
What should I include in my comments to the FCC?
We recommend including the following key points in your comments to the FCC.
- The ability to receive and send texts from a toll-free number is an invaluable means to communicate with customers.
- The existing process for text enabling numbers is easy and effective. The process enables us to confirm our control over the number in a simple and quick manner. The FCC should not burden our authority by inserting another entity into the process.
- Once a business or organization is allocated a toll-free number, it should not have to report to the RespOrg about how it will use the number. This requirement only adds costs without protecting us, the subscriber, in any way.
- The proposal would unnecessarily impose regulatory costs and additional burdens on business toll-free subscribers. It is opposite to the FCC’s de-regulatory agenda.
- We are concerned about what kind of enforcement efforts the FCC would take against toll-free subscribers who, for any reason, fail to inform (or delay informing) their RespOrg of their text-enablement.
- RCS (Rich Communication Services) messaging is about to launch across the entire industry, eventually replacing SMS. Regulating toll-free texting at such a critical juncture would be irresponsible and significantly hinder the ability of RCS to grow and expand.
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