2017

Apr 18, 2017 // by admin // Compliance, Guidelines & Regulations, SMS Mobile Technology

CITIA

Short Code Monitoring Program

Version 1.7

Effective Date March 27, 2017

INTRODUCTION

CTIA and its member companies work to protect consumers while fostering a competitive environment for shortcode programs. We aim to

■ Provide consumers the best possible user experience;

■ Honor consumer choices and prevent abuse of messaging platforms;

■ Deliver flexible guidelines that communicate compliance values clearly;

■ Enable the short code industry to self-regulate; and

■ Facilitate enforcement measures, if necessary, to protect consumers quickly and consistently.

The Short Code Compliance Handbook (Handbook) guidelines lay the framework for achieving these goals, butCTIA reserves the right to take action against any short code program deemed to cause consumer harm.

The Handbook is not intended as a comprehensive guide to compliance with laws and regulations that apply toshort code programs. Service providers are responsible for meeting legal requirements that apply to short codeprograms they offer, and CTIA and its members make no representation that meeting the guidelines in this

Handbook is sufficient to assure legal compliance. Consultation with legal counsel is recommended stronglly.

ABOUT THIS HANDBOOK

This Handbook describes best practices for standard rate messaging services (SMS), multimedia messagingservices (MMS), and free-to-end user (FTEU) short code programs with the primary goal of providing the best

customer experience for users. Handbook guidelines do not define rules for programs that bill consumers.

Guidelines are organized according to use cases that apply. Examples of compliant programs are organized byuse case in the appendice

Carriers reserve the right to implement their own short code program requirements beyond the scope of this Handbook. However, all carriers have reviewed and accepted the Handbook’s content.

This Handbook is divided into the following sections: Compliance Framework, In-Market Monitoring Guide, Audit

Standards Guide, and Audit Standards. In addition, Appendix A and Appendix B detail sample compliant

programs, and Appendix C describes common terms.

REFERENCES

Drawing from experience working with short code programs, the guidelines evolve continually. Handbook vl .7 is

based on the following:

■ Mobile Marketing Association’s Consumer Best Practices v7.0,

■ CTIA Mobile Compliance Assurance Handbook vl .3,

■ California Attorney General Kamala D. Harris’s “Privacy on the Go: Recommendations for the Mobile

Ecosystem” best practices,

■ Telephone Consumer Protection Act (TCPA),2

■ Florida Attorney General’s requirements for mobile content,

■ A2P (application-to-person) community feedback, and

■ Carrier requirements

COMPLIANCE FRAMEWORK

This section offers direction regarding compliance of short code programs, including guidelines and requirements.

Nonetheless, following this handbook is no guarantee that a short code program is compliant. Short code

programs might also need to comply with individual carrier requirements.

UNIVERSAL COMPLIANCE PRINCIPLES

CTIA requires all short code programs to comply with a basic code of conduct that promotes the best possible

user experience. As new uses for short codes emerge, the guiding principles in section A.1 should be considered

when defining applicable rules. Short code programs that comply technically with the letter of a specific rule but

violate the letter or spirit of these principles might be subject to enforcement action.

A.1 GUIDING PRINCIPLES

Four principles provide the baseline for all requirements listed below

1. Display clear calls-to-action. All programs must display a clear call-to-action. Customers must be made

aware of what exactly they are signing up to receive.

2. Offer clear opt-in mechanisms. Customers must consent clearly to opt into all recurring-messages

programs. Requiring a customer to enter a mobile phone number does not constitute a compliant opt-in.

Instead, customers must understand they will receive messages and consent to receive them.

3. Send opt-in confirmation messages. A confirmation message must be sent to customers always. For

recurring-messages programs, confirmation messages must include clear opt-out instructions.

4. Acknowledge opt-out requests. Short code service providers must acknowledge and act on all opt-out

requests. Monitoring procedures confirm successful opt-out.

A.2 CHOICE AND CONSENT

Short code programs are expected to deliver sufficient value so consumers elect to participate with full

transparency into the delivery conditions.

A.2.01 UNSOLICITED MESSAGES

Unsolicited messages may not be transmitted using short codes. Unsolicited messages are defined as follows:

■ Messages delivered without prior express consent from the user or account holder, and

■ Messages sent after a user has opted out.

A.2.02 MARKETING CONTEXT

No component of program advertising or messaging may be deceptive about the underlying program’s

functionality, features, or content. All disclosures present in pre-purchase calls-to-action, advertisements, terms

and conditions, and messages must remain clear and consistent throughout the user experience.

A.2.03 OPT-IN

Messages must be delivered to a consumer’s mobile device only after the user has opted in to receive them. A

user might indicate interest in a program in several ways. For example, a user might

■ Enter a phone number online,

■ Click a button on a mobile webpage,

■ Send an MO message containing an advertising keyword,

3 Sending the user a single opt-out message acknowledging the opt-out request is the only exception to this rule.

■ Sign up at a point-of-sale (POS) location, or

■ Opt in over the phone using interactive voice response (IVR) technology.

Calls-to-action must be clear and accurate; consent must not be obtained through deceptive means. For example,

opt-in details cannot be displayed obscurely in terms and conditions related to other services. Enrolling a user in

multiple short code programs based on a single in is prohibited, even when all programs operate on the same

short code.

Recurring-messages short code programs should send a single opt-in confirmation message that displays

information verifying the customer’s enrollment in the identified program. The opt-in confirmation message must

be delivered immediately after the customer opts into the program. For POS and hardcopy opt-ins, the opt-in

confirmation message must be delivered as soon as is reasonably possible after the customer opts into the

program. Additionally, opt-in messages must contain the program (brand) name or product description, customer

care contact information, opt-out instructions, product quantity or recurring-messages program disclosure, and the

“message and data rates may apply” disclosure.

The opt-in for all short code programs must comply with all legal and regulatory requirements, including the

Telephone Consumer Protection Act, 47 U.S.C. § 227, and the Federal Communication Commission’s rules under

47 C.F.R. § 64.1200. For example, the express written consent obtained for any program that is “telemarketing”

[as defined by 47 C.F.R. § 64.1200(f)(14)] must, unless exempt from the requirement, include the elements of

“prior express written consent” set forth in 47 C.F.R. § 64.1200(f)(8). That rule requires a clear and conspicuous

disclosure informing the user that:

■ By opting in, the user authorizes the seller to deliver or cause to be delivered to the user marketing

messages using an automatic telephone dialing system; and

■ The user is not required to opt in (directly or indirectly) as a condition of purchasing any property, goods,

or services.

Legacy double optin (i.e., mobile device confirmation) methods remain acceptable options to obtain express consumer consent.

A.2.04 OPT-OUT

Functioning opt-out mechanisms are crucial for all text messaging programs. Programs must always acknowledge

and respect customers’ requests to opt out of programs. However, depending on the use case, some short code

programs are not required to advertise opt-out instructions. Short code programs must respond to, at a minimum,

the universal keywords STOP, END, CANCEL, UNSUBSCRIBE, and OUIT by sending an opt-out message and, if

the user is subscribed, by opting the user out of the program. Subsequent text, punctuation, capitalization, or

some combination thereof must not interfere with opt-out keyword functionality.

Recurring-messages programs must also display opt-out instructions at program opt-in and at regular intervals in

content or service messages, at least once per month. Opt-out information must be displayed on the

advertisement or within the terms and conditions.4 A program may deliver one final message to confirm a user

has opted out successfully, but no additional messages may be sent after the user indicates a desire to cancel a

short code program.

A.3 CUSTOMER CARE

Customer care contact information must be clear and readily available to help users understand program details

as well as their status with the program. Customer care information should result in users’ receiving help.

Programs must always respond to customer care requests, regardless of whether the requestor is subscribed to

the program. At a minimum, the HELP keyword must return the program name and further information about howto contact service providers. Short code programs should promote customer care contact instructions at

program opt-in and at regular intervals in content or service messages, at least once per mon4 Opt-out information no longer need appear in bold typeface.

A.4 PROGRAM CONTENT

All content associated with short code programs must promote a positive user experience. Carriers regulate

certain types of content, including those listed in this section

A.4.01 UNAPPROVED OR ILLICIT CONTENT

No programs associated with carrier brands or operating on the carrier networks may promote unapproved or

illicit content, including the following:

■ Depictions or endorsements of violence,

■ Adult or otherwise inappropriate content,

■ Profanity or hate speech, and

■ Endorsement of illegal or illicit drugs.

Programs must operate according to all applicable federal and state laws and regulations. All content must be

appropriate for the intended audience. Additional legal and ethical obligations apply when marketing to children

under age 13, and such programs might be subject to additional review by carriers.

A.4.02 CONTROLLED SUBSTANCES

Promotions of controlled substances might be subject to additional review by carriers. Service providers must

receive explicit carrier approval before launching these program types. Marketing of hard alcohol and tobacco

brands must either include robust age verification (e.g., electronic confirmation of age and identity) at opt-in orestrict promotions to ageverified locations (e.g., points of sale in bars). Mobile programs must not promote theuse of controlled substances directly. Reference to the abuse of controlled substances is prohibited.

A.4.03 SWEEPSTAKES AND CONTESTS

Sweepstakes are characterized by the element of chance and the outcome of a prize. Both state and federal laws

regulate sweepstakes. Organizations considering a sweepstakes program are urged to consult with their legal

counsel before submitting a program for carrier approval. Carriers review sweepstakes individually and reserve

the right to approve or reject them at their discretion. Note that sweepstakes program review might take longer

than reviews of other program types. At a minimum, sweepstakes program providers should

■ Follow each carrier’s process and guidelines,

■ Provide the carrier with the sweepstakes rules for review,

■ Include a free method of entry, and

■ Consult with legal counsel.

A.4.04 CONTENT DELIVERY

Users should be informed of the next steps to download and store new content immediately after opt-in. Content

must be delivered correctly and must function as advertised.

A.5 PRIVACY POLICY AND TERMS AND CONDITIONS

Service providers are responsible for protecting the privacy of user information and must comply with applicable

privacy law. Service providers should maintain a privacy policy for all programs and make it accessible from the

initial call-to-action. When a privacy policy link is displayed, it should be labeled clearly.

Use cases might require different disclosures in the full terms and conditions. In all cases, terms and conditi and privacy policy disclosures must provide up-todate, accurate information about program details and

date, accurate information about program details and functionality.

A.6 PROGRAM NAME AND PRODUCT DESCRIPTION

Consistent program names and product descriptions in advertisements and messages help consumers connect

all parts of the short code experience. All short code programs are required to disclose program names, product

description, or both in service messages, on the call-to-action, and in the terms and conditions. The program

name is the sponsor of the short code program, often the brand name or company name associated with the short code. The product description describes the product advertised by the program.

A.7 PROGRAM RECORDS AND FUNCTIONALITY

Service providers assume responsibility for maintaining accurate records in carrier systems and the Common

Short Code Administration (CSCA) registry. Service providers wishing to modify a program must submit changes

to the carriers for review and must update relevant carrier records. Programs promoted in the market must matcthe programs approved.

A.7.01 CUSTOMER RECORDS

All opt-in and opt-out requests should be retained from the time a user initiates opt-in until a minimum of six

months after the user has opted out of a program. Service providers assume responsibility for managing

information about deactivated and recycled mobile phone numbers and must process this information within three business days of receipt. After porting a mobile phone number between carriers, the user must opt in again to

desired programs.

Service providers must track opt-in information by individual users. Selling mobile opt-in lists is prohibited.

A.7.02 MO MESSAGE PROCESSING

All mandatory keywords must be processed correctly, regardless of MO message format (e.g., keywords must

function whether sent by MMS or SMS). Service providers must scan MO message logs regularly to identify opt-

out attempts and must terminate those subscriptions, regardless of whether the subscribers used the correct opt-

out keywords or methods.

USE CASES

Because short code programs vary greatly, depending on their intended purpose, Handbook vl .5.0 was designed

with different use cases in mind. All short code programs based on the displayed use cases must comply with the

Universal Compliance Principles in addition to the specific guidelines described in this section.

A.8 SINGLE-MESSAGE PROGRAMS

Single-message programs, or “one-off programs, deliver a one-time message in response to user opt-in

requests. Examples of single-message programs include but are not limited to the following:

■ Informational alert,

■ Purchase receipt,

■ Delivery notification, and

■ Two-factor authentication.

An example of a compliant single-message program and associated message flow appears in Append6

Description Requirements Call-to-Action The call-to-action for a singlemessageprogram can be simple. The primary

messageprogram can be simple. The primary program can be simple. The primary program can be simple. The primary purpose of disclosures is to ensure a consumer consents to receive a text message and understands the nature of the program.

Product description Complete terms and conditions, link to terms and conditionsPrivacy policy or link to privacy policy

Privacy policy or link to privacy policy “Message and data rates may apply” disclosure Terms and Conditions
Comprehensive terms and conditions may

be presented in full beneath the call-to- action, or they be may accessible from a link in proximity to the call-to-action.5

Program (brand) identification

Product description

Customer care contact information

“Message and data rates may apply”

disclosure Opt-ln

The consumer must actively opt into single¬message programs.

Consumer’s affirmative opt-in Message Flow Although single-message programs are not

required to display HELP and STOPkeywords, they should support HELP and

STOP commands, as described in the Universal Compliance Principles.
Opt-ln Confirmation MT

■ Program (brand) name OR product description

HELP MT

■ Program (brand) name OR product description

■ Additional customer care contact information

Opt-Out MT

■ Program (brand) name OR product description

■ Confirmation that no further messages will be delivered
Exhibit 1: SINGLE-MESSAGE PROGRAM USE CASE QUICK REFERENCE GUIDE

A.9 RECURRING-MESSAGES PROGRAMS

A user opts into a recurring-messages program by texting a keyword to the program’s short code, entering his or

her mobile phone number online or agreeing in apps or in person to receive text messages. Examples of

recurring-messages programs include but are not limited to the following:

■ Content or informational alert subscriptions (e.g., horoscopes, news, weather),

■ Flight status notifications (multiple messages), and

■ Marketing and loyalty promotions.

An example of a compliant recurring-messages program call-to-action and associated message flow appears in

Appendix B.

Description

Requirements Call-to- Because  of  their  ongoing  touch  points  with
■ Product  descriptionAction
consumers,  recurring-messages  programs

require the most disclosures among use

cases. The primary purpose of disclosures is

to ensure the consumer consents to receive

text messages and understands the nature

of the program.
■

■

■
Service delivery frequency or recurring-

messages disclosure

Complete terms and conditions, link to

complete terms and conditions

■
STOP keyword

■
“Message and data rates may apply”

disclosure
Terms and

Conditions
Comprehensive terms and conditions might

be presented in full beneath the call-to-

action, or they might be accessible from a

link in proximity to the call-to-action.7
■

■

■
Program (brand) name

Service delivery frequency or recurring-

messages disclosure

Product description

Customer care contact information

Opt-out instructions

■
“Message and data rates may apply”

disclosure
Opt-ln
Consumers must provide prior express

written consent to enroll in all text message

programs (i.e., single-message programs or

recurring-messages programs). Recurring-

messages programs must send one

message confirming opt-in consent. Double

opt-in is optional.
■
Consumer’s affirmative opt-in
Message

Flow
Recurring-messages programs confirming

opt-in with a single text message MUST

state explicitly to which program the user

enrolled and provide clear opt-out

instructions in the Opt-ln Confirmation MT.
Opt-ln Confirmation MT

■ Program (brand) name OR product description

■ Opt-out information

■ Customer care contact information

■
Product quantity or recurring-messages

disclosure

■
“Message and data rates may apply”

disclosure

HELP MT

■

■
Program (brand) name OR product description

Additional customer care contact information

Opt-Out MT

■
Program (brand) name OR product description

■
Confirmation that no further messages will be

delivered
Exhibit 2: RECURRING-MESSAGES PROGRAM USE CASE QUICK REFERENCE GUIDE

Out-Out information may appear on a separate page in the terms and conditions.

Popups have been removed as a method for displaying terms and conditA.10

MACHINE-TO-MACHINE PROGRAMS

For machine-to-machine (M2M) short code programs, which should never interact with consumers, service

providers need only an updated program brief on file with the CSCA and the carriers.

A.11 PREMIUM RATE POLITICAL DONATION PROGRAMS

Premium rate short code programs that solicit political donations are subject to additional regulations, available at

http://www.ctia.org/policv-initiatives/voluntarv-guidelines/federal-political-campaign-contributions-wireless-carrier-

bill. Premium political donation programs also must conform to the premium SMS guidelines and audit standards

in the CTIA Mobile Commerce Compliance Handbook, vl.3.

A.12 PREMIUM RATE CHARITABLE DONATION PROGRAMS

Premium rate short code programs that solicit charitable donations are subject to additional regulations, available

at http://www.ctia.org/policv-initiatives/voluntarv-guidelines/mobile-giving-via-wireless-carrier%27s-bill. In addition,

premium charitable donation programs must to conform to the premium SMS guidelines and audit standards in

CTIA Mobile Commerce Compliance Handbook, vl.3.

A.13 FREE-TO-END-USER PROGRAMS

FTEU programs are subject to almost all of the same requirements as SMS short code programs. FTEU

programs must display a clear call-to-action, capture consumers’ affirmative opt-in, send an opt-in confirmation

message, and abide by customers’ requests to opt-out. However, all FTEU programs are exempt from displaying

“message and data rates may apply” in advertisements, terms and conditions, and messages.

A.14 MMS PROGRAMS

MMS programs are subject to the same requirements per use case as SMS short code programs. All mandatory

keywords must be processed correctly, regardless of MO format (e.g., keywords must function whether sent by

MMS or SMS). Service providers must scan MO logs regularly to identify opt-out attempts and must terminate

associated subscriptions, regardless of whether the subscribers used the correct opt-out keywords or methods.

A.15 INTERACTIVE CUSTOMER CARE CHAT PROGRAMS

Because rapid and direct communication between customers and customer care representatives is important,

many organizations now offer interactive customer care chat programs. Such communication makes obtaining

assistance with minimal delay easier and more convenient for customers. For example, customers replying with

the HELP keyword to a short code can be routed quickly to customer care, where they can chat directly with a

representative, without ever leaving their messaging application. Increasing prevalence of this communication

practice makes understanding the guidelines and limitations surrounding such programs more important than ever

for carriers. For organizations wishing to implement interactive customer care chat, such programs

■ May operate on dedicated short codes only;

■ May be used for communication with customer care representatives only; and

■ May not be used for marketing.

CARRIER ONBOARDING

CTIA is most concerned with short code programs as they interact with consumers through advertising and

service messaging. However, several facets of SMS programs happen behind the scenes. Recommended best

practices for onboarding new programs follow.9Carriers may maintain individual playbooks tailored to their customers’ needs and must sometimes respond to

emerging risks that fall outside the Handbook. Refer to carriers’ playbooks for onboarding information regarding

■ Program certification and migration processes,

■ Program brief details,

■ Advertising of controlled substances,

■ Sweepstakes approval processes, and

■ Marketing to children.

10 Definition
Cure  Date
Penalties
Severity  0
Extreme  consumer harm
Immediate
CTIA:  Immediate  registry  suspension

Carriers: Vary by case; immediate suspension or termination possible
Severity 1 Serious consumer

harm
5 business days
CTIA: Unresolved audits; possible registry

suspension

Carriers: Vary by case
Severity 2
Moderate

consumer  harm
5  business  days
CTIA:  Vary  by  case

Carriers: Vary by case
IN-MARKET MONITORING GUIDE

In this section, in-market monitoring, including details about audit notices, communication, retests, and appeals, is

explained.

COMPLIANCE AUDITS

The CTIA Compliance Assurance Solution employs data gathered via in-market monitoring. When programs are

deployed in market, the live programs are captured and audited. This method is more effective than program brief review or routine keyword testing because compliance audits reflect the user experience that actual consumers

encounter when they interact with short code programs in market.

CTIA issues compliance audits weekly for standard rate short codes leased with the CSCA. Compliance audits

performed by CTIA are available to all major U.S. carriers, and CTIA compliance metrics can be incorporated into

individual carrier compliance policies.

A.16 AUDIT NOTICES

CTIA distributes Audit Notices each week. Each audit notice displays a unique audit number, short code, service

provider, aggregator or aggregators, notice date, and cure date at the top. Individual violations are classified as

Severity 0, Severity 1, or Severity 2, based on their potential for consumer harm, with Severity 0 representing the

most extreme violations. Violations are based on the compliance guidelines outlined in the Compliance

Framework section of the Handbook. Taking the severity level of the gravest violation cited, a failed audit must be

resolved in the appropriate timeframe (i.e., before or on the cure date).

A.17 SCHEDULE

CTIA compiles and generates audit notices each Monday for audits performed the previous week, and audits are

published Tuesday at 2:00 A.M. EST. Although audits might be available for review earlier, the official notice date

from which the cure date is calculated is 12:00 P.M. EST each Tuesday.

A.18 SEVERITY LEVELS

All audit notices are assigned severity levels based on the extent to which the associated findings might harm

consumers. Cure dates and penalties vary based on severity, as detailed in Exhibit 3.

EXHIBIT 3: AUDIT NOTICE SEVERITIES DESCRIPTION

A.19 CTIA COMPLIANCE CARE TEAM COMMUNICATION

On receiving an audit notice, service providers may communicate with the CTIA compliance care team by leaving

a comment on the audit notice or contacting us.support@wmcglobal.com. The CTIA Compliance Care Team

(Care Team) responds promptly to all messages. Although Care Team specialists are unable to preapprove

compliant designs, they assist service providers as much as possible with understanding how to resolve violations

and close their audits.

A.20 RETESTS

Within the prescribed period following issuance of an audit notice, the responsible aggregator or service provider

must confirm on the audit notice that it has made changes to or has removed from market the offending

advertisement or message flow. Should the CTIA Compliance Care Team fail to receive confirmation or should

the service provider fail to take the actions required, the short code is subject to further action.

In the case of TV and print advertisements with longer run cycles, aggregators and service providers may submit

a retest request for a rerelease date. Retest requests must be made in good faith, with a clear explanation of the

changes implemented. Audits at this status are categorized as Pending Retest.

A.21 APPEALS

Aggregators and service providers that believe they have a valid claim may challenge an audit by contacting

us.support@wmcglobal.com before the cure date noted on the audit notice. The email message should explain

why the service provider deems the audit incorrect. Appeals must pertain to the application of violations cited on

the specific audit in question.

AUDIT STANDARDS GUIDE

The following pages display tables of audit standards by use case. Advertising audit standards apply to all

advertisements hosting calls-to-action for short code programs; message flow audit standards apply to required

service messages.

Message categories for which specific standards apply are marked with an “x” in the tables. Refer to the glossary

below for help with unfamiliar terms.

Opt-ln

Confirmation
Short code programs should send a single opt-in confirmation message displaying

information verifying the customer’s enrollment in the identified program and describing

how to opt out. The opt-in confirmation message must be delivered immediately after the

customer opts into the short code program. Additionally, opt-in messages must contain

the program (brand) name or product description, customer care contact information,

product quantity or recurring-messages program disclosure, and the “message and data

rates may apply” disclosure.
HELP
Message service providers send a HELP message after customers text the HELP

keyword. Short codes should reply with additional contact information to customer

requests for help.
Opt-Out
Message service providers send an opt-out message after customers text the STOP

keyword. The opt-out message confirms that the customer has been opted out of the

program.
Violation
Specific breach of the Universal Compliance Principles. Auditors check program

advertisements and service messages against lists of violations to identify

noncompliance.
Severity
Number representing the customer impact associated with a violation. Severity 0

violations  impact  customers  most.  Severity  2  violations  are  least  customer  impacting.
Action  Required
Action  or  actions  the  responsible  service  provider  must  take  to  correct  the  associated

violation.
AUDIT STANDARDS

The audit standards listed below distill the principles listed in the narrative portion of the Handbook into test

scripts for monitoring. Advertising audit standards apply to media displaying short code calls-to-action. Message

flow audit standards apply to required service messages.

SINGLE-MESSAGE PROGRAMS

A.22 SINGLE-MESSAGE PROGRAM ADVERTISING AUDIT STANDARDS

A.23 SINGLE-MESSAGE PROGRAM MESSAGE FLOW AUDIT STANDARDS

Violation
Severity
Action Required
Contains or promotes SHAFT (sex, hate, alcohol, firearms,

or tobacco) content
0
Remove call-to-action associated with SHAFT (sex, hate,

alcohol,  firearms,  or  tobacco)  content
Fails  to  match  approved  program  in  CSC  registry
1
Remove  unapproved  program  elements  or  update  CSC  registry
No  clear  indication  of  privacy  policy
1
Display  privacy  policy  or  clearly  labeled  link  to  privacy  policy
No  link  to  comprehensive  T&Cs
1
Display  link  to  comprehensive  T&Cs
No  product  or  service  description
1
Describe  product  or  service
Improper  use  of  the  term  free
1
Remove  the  term  free
Failure  to  display  STOP  keyword
1
Display  STOP  keyword8
No  mention  that  messages  are  recurring
2
State  that  messages  are  recurring
No  mention  that  message  and  data  rates  may  apply
2
Disclose  that  message  and  data  rates  may  apply
No  customer  care  contact  information9
2
Display  toll-free  helpline,  email  address,  or  HELP  keyword
Violation
Severity
Action  Required
Applicable  Message
Opt-ln

Conf.
HELP
Opt-

Out
Contains or promotes SHAFT (sex,

hate, alcohol, firearms, or tobacco)

content
0
Remove call-to-action associated with

SHAFT (sex, hate, alcohol, firearms, or

tobacco) content
X
X
X
Fails to match approved program in

CSC registry
1
Remove unapproved program elements or

update  CSC  registry
X
X
X
Unsolicited  message  delivered
1
Cease  all  messaging  associated  with

program
X
X
X
Failure to display STOP keyword
1
Display STOP keyword
X

Incorrect response to STOP command
1
Terminate all of customer’s active programs

after he or she texts STOP, and send one

opt-out message

X
No indication that program is recurring
2
State that program is recurring
X

No  product  or  program  name
2
Display  program  or  product  name
X
X
X
No  mention  that  message  and  data

rates may apply
2
Disclose that message and data rates may

apply
X

No customer care contact information
2
Display toll-free helpline, email address, or

HELP keyword10
X

Failure to reply to HELP keyword
2
Reply to HELP keyword with additional

contact information (e.g., a toll-free helpline

or email address)

RECURRING-MESSAGES PROGRAMS
A.24 RECURRING-MESSAGES PROGRAM ADVERTISING AUDIT STANDARDS

A.25 RECURRING-MESSAGES PROGRAM MESSAGE FLOW AUDIT STANDARDS

Violation
Severity
Action  Required
Failure  to  match  approved  program  in  CSC  registry
1
Remove  unapproved  program  elements  or  update  program

details in CSC registry
A.26 MACHINE-TO-MACHINE PROGRAM AUDIT STANDARDS

M2M programs, which should never interact with consumers, only need keep an updated program brief on file

with the CSCA and the carriers. If an M2M program is found advertising to consumers, it is subject to immediate

enforcement action.

APPENDIX A:

SAMPLE COMPLIANT SINGLE-MESSAGE PROGRAM

Exhibit Al: Sample Compliant Single-Message Advertisement

and Service Messages

Opt-ln Confirmation Message:

“Coupon King: Show this text at the register for 50%

off your next purchase!”

HELP Message:

“Thanks for texting Coupon King! Call 1-800-123-

4567 for support.”

Opt-Out Message:

“Coupon King: You will receive no further messages.”

Exhibit A2: Sample Compliant Single-Message Advertisement

and Service Messages

Opt-ln Confirmation Message:

“Mobile Confirm: Your passcode is 9876. Enter it

online to confirm your account.”

HELP Message:

“You recently created or modified an account online.

Enter your passcode to confirm. Call 1-800-123-4567

for Mobile Confirm support.”

Opt-Out Message:

“Mobile Confirm: You will receive no further

messages from short code 12345.”

Exhibit A3: Sample Compliant Single-Message Print Advertisement

and Service Messages

Opt-ln Confirmation Message:

“Best Realty: Go to bestrealty.com/housel for more

info on this property.”

HELP Message:

“For Best Realty property info help, contact

smshelp@bestrealty.com.”

Text HOUSE1 to get more info on

this property from Best Reolty

Msg&dota rotes moy apply Go to

website.com/sms for privacy and

terms info.
Opt-Out Message:

“You’re opted out and will no longer receive Best

Realty property info alerts.”

Exhibit A4: Sample Compliant Single-Message Verbal Opt-ln

and Service Messages

Would you like a one-time reminder of your upcoming flight? We’ll

text the mobile number you provide with the flight status 24 hours

before your scheduled departure. Message and data rates may

apply. You can visit our website at flights.com/sms for privacy and

terms information.

✓

V__

Opt-ln Confirmation Message:

“Reminder: Your flight leaves tomorrow at 4:05 P.M.

from Gate 1.”

HELP Message:

“For assistance with Flight Reminder messages, call

1-888-123-4567.”

Opt-Out Message:

“You are now opted out and will receive no further

Flight Reminder messages.”

Exhibit A5: Sample Compliant Single-Message Hardcopy Opt-ln

and Service Messages

Lifetime Trip – Enrollment Form

Enter your name ond mobile number to receive o one-time

alert when o spot opens up on our waiting list

Message and data rates may apply Go to website com/sms for

privacy and terms info

Name_

Mobile Number_
Opt-ln Confirmation Message:

“A spot just opened up on the Lifetime Trip waiting

list. Contact your travel agent to sign up today!”

HELP Message:

“For Lifetime Trip waiting list help, call 1-888-123-

4567.”

Opt-Out Message:

“You’re now opted out and will no longer receive

Lifetime Trip wait list alerts.”

APPENDIX B:

SAMPLE COMPLIANT RECURRING-MESSAGES PROGRAM

Exhibit Bl: Sample Compliant Recurring-Messages Web Advertisement

and Service Messages11

Opt-ln Confirmation Message:

“You’re now subscribed to daily Weather Alerts.

Reply STOP to cancel at any time. Call 1-800-123-

4567 for support. Message and data rates may

apply.”

HELP Message:

“Contact us at 1-800-123-4567 with questions about

Weather Alerts.”

Opt-Out Message:

“You have opted out of Weather Alerts and will

Although opt-out instructions are not required on

the advertisement itself, they must appear in the

terms and conditions.

Terms and Conditions

Complete terms and conditions should include

customer care contact information; complete opt-

out instructions; a recurring message disclosure,

a product description and a program (brand)

name. Some program types (e.g., sweepstakes)

have additional requirements carrier by carrier.
receive no further messages.”

Opt-out information no longer need appear in bold typeface.

v__

Although opt-out instructions are not required on

Exhibit B2: Sample Compliant Recurring-Messages TV Advertisement

and Service Messages

Opt-ln Confirmation Message:

Text OFFERS to 12345 for ongoing offer alerts “You’ll now receive special offers from Good Brands!

Reply STOP to opt-out. Email

help@goodbrands.com with questions. Msg&Data

Message and data rates may apply

rates may apply.”

Text STOP to cancel or HELP for help

Go to offerscom/terms for privacy and terms

HELP Message:

help@goodbrands.com or call 1-888-123-4567 for

support.”

Opt-Out Message:

the advertisement itself, they must appear in the

“Good Brands. You will receive no further messages

terms and conditions.

from short code 12345.”

Terms and Conditions

Complete terms and conditions should include

customer care contact information, complete opt-

out instructions, a recurring message disclosure,

a product description, and a program (brand)

name. Some program types (e.g., sweepstakes)

have additional requirements carrier by carrier.

Exhibit B3: Sample Compliant Non-Marketing Recurring-Messages Opt-ln

and Service Messages

>- Opt-ln Confirmation Message:

Wont to sign up for appointment reminder

“Doctor Message thanks you for enrolling! You’ll now

texts? We’ll send you on opt-in message

receive appointment reminders. Text HELP for help.

Message and data rotes may apply

Reply STOP to cancel. Msg&Data Rates May Apply.”

Recurring-Messages Appointment Reminder

Service representative records customer’s request

for messages and customer’s phone number.

Program terms and conditions, including complete

opt-out information, and privacy policy are available

from the representative.
HELP Message:

“Email help@doctormessage.com for support with

appointment reminders service. Reply STOP to

cancel.”

Opt-Out Message:

“You are now opted out of Doctor Message

appointment reminders. You will receive no further

messages.”

Exhibit B4: Sample Compliant Recurring-Messages Web Keyword Advertisement

and Service Messages

Opt-ln Confirmation Message:

“You’re now subscribed to weekly deal alerts from

Good Brands! Reply STOP to cancel. Msg&data

rates may apply. Contact help@goodbrands.com for

customer support.”

HELP Message:

“For Good Brands weekly deal alerts support, email

help@goodbrands.com or call 1-888-123-4567.”

Opt-Out Message:

“You’re opted out and will no longer receive Good

Brands deal alerts.”

Exhibit B5: Sample Compliant Single-Message POS Advertisement

and Service Messages

Opt-ln Confirmation Message:

“For a copy of your receipt, click here:

shorturl.com/eu38re8w.”

To receive o message with a link to your receipt,

enter your mobile number:

Sign Up1 |

Messoge and data rotes may apply

Visit websitecom/sms for privacy and terms info
HELP Message:

“For Store Receipt help, call 1-888-123-4567.”

Opt-Out Message:

“You’re opted out and won’t receive any more Store

Receipt messages.”

Exhibit B6: Sample Compliant Recurring-Messages POS Advertisement

and Service Messages

Opt-ln Confirmation Message:

“You’re subscribed to Good Brand sale alerts!

Msg&data rates may apply. Reply STOP to opt out.

To receive periodic Good Brand sale alert messages,

enter your mobile number

Message and data rates may apply

Text STOP to opt out and HELP for help

Visit website com/sms for privacy ond terms info.
Contact help@goodbrands.com with questions.”

HELP Message:

“For Good Brands sale alerts support, email

help@goodbrands.com or call 1-888-123-4567.”

Opt-Out Message:

“You’re opted out and will no longer receive Good

Brands sale alerts.”

Exhibit B7: Sample Compliant Recurring-Messages Hardcopy Advertisement

and Service Messages

Opt-ln Confirmation Message:

“You’re now subscribed to receive Best Realty

Best Realty Sign-In Form

Please enter your name and mobile number to receive weekly

open house alerts.

Message and data rates may apply Go to website com/sms tor

privacy and terms info Text STOP to opt oat and HELP for

help

Name_

Mobile Number_
weekly open house alerts. Msg&data rates may

apply. Text STOP to opt out. Text HELP for more

info.”

HELP Message:

“For Best Realty open house alerts help, email

help@bestrealty.com or call 1-888-123-4567.”

Opt-Out Message:

“You’re opted out of open house alerts and will no

longer receive messages from Best Realty.”

Term
Description
Audit Notice
Report issued to noncompliant short code programs detailing the specific violations

and actions required to bring the program into compliance
Call-to-Action
Language urging a customer to opt into a short code program, and the mechanism

(e.g.,  button  displaying  “buy  now”)  allowing  them  to  do  so
Compliance  Audit
Test  performed  to  determine  the  compliance  of  a  short  code  program
Consent
Act  of  agreeing  to  opt  into  a  short  code  program  and  the  terms  and  conditions

associated  with  the  purchase
Content  Message
Text  message  delivering  purchased  content  or  displaying  instructions  for  how  to

access  purchased  content
Message  Platform
Application  through  which  messages  are  received  and  sent
Mobile  Originated

(MO)
Text message sent from a user’s mobile device
Mobile Terminated

(MT)
Text  message  sent  to  user  in  response  to  user  texting  a  keyword
Service  Message
Text  message  offering  details  about  the  short  code  program,  including  opt-in

instructions, opt-out instructions, summary terms and conditions, and support

information  (e.g.,  helpline)
Short  Code  Program
Program  to  which  a  user  opts  in  by  entering  a  short  code

APPENDIX C: COMMON TERMS

TABLE OF CONTENTS

VERSION HISTORY 1

INTRODUCTION 2

About This Handbook 2

References 2

COMPLIANCE FRAMEWORK 3

Universal Compliance Principles 3

A.1 Guiding Principles 3

A.2 Choice and Consent 3

A.2.01 Unsolicited Messages 3

A.2.02 Marketing Context 3

A.2.03 Opt-ln 3

A.2.04 Opt-Out 4

A.3 Customer Care 4

A.4 Program Content 5

A.4.01 Unapproved or Illicit Content 5

A.4.02 Controlled Substances 5

A.4.03 Sweepstakes and Contests 5

A.4.04 Content Delivery 5

A.5 Privacy Policy and Terms and Conditions 5

A.6 Program Name and Product Description 6

A.7 Program Records and Functionality 6

A.7.01 Customer Records 6

A.7.02 MO Message Processing 6

Use Cases 6

A.8 Single-Message Programs 6

A.9 Recurring-Messages Programs 7

A.10 Machine-to-Machine Programs 9

A.11 Premium Rate Political Donation Programs 9

A.12 Premium Rate Charitable Donation Programs 9

A.13 Free-to-End-User Programs 9

A.14 MMS Programs 9

A.15 Interactive Customer Care Chat Programs 9

Carrier Onboarding

IN-MARKET MONITORING GUIDE 11

Compliance Audits 11

A.16 Audit Notices 11

A.17 Schedule 11

18 Severity Levels 11

A.19 CTIA Compliance Care Team Communication 12

A.20 Retests 12

A.21 Appeals 12

AUDIT STANDARDS GUIDE 13

AUDIT STANDARDS 14

Single-Message Programs 14

A.22 Single-Message Program Advertising Audit Standards 14

A.23 Single-Message Program Message Flow Audit Standards 14

Recurring-Messages Programs 15

A.24 Recurring-Messages Program Advertising Audit Standards 15

A.25 Recurring-Messages Program Message Flow Audit Standards 15

A.26 Machine-to-Machine Program Audit Standards 16

APPENDIX A: SAMPLE COMPLIANT SINGLE-MESSAGE PROGRAM 17

APPENDIX B: SAMPLE COMPLIANT RECURRING-MESSAGES PROGRAM 20

APPENDIX C: COMMON TERMS

Version	Release Date		Details
1.5.2	October 1,2015	The CTIA Short Code Monitoring Handbook was updated with the following: ■ Guiding Principles section; ■ Unsolicited messages definition update; ■ Recurring-messages short code program opt-in guideline update; ■ Program name and product description guidelines; ■ Free-to-end-user program requirements; and ■ Appendix C: Common Terms.
1.6	July 15, 2016	The CTIA Short Code Monitoring Handbook was updated with the following: ■ Version history for handbook updates; ■ Sweepstakes and contests guidelines; ■ Opt-out information formatting update; ■ Interactive customer care chat programs guidelines; ■ New SHAFT (sex, hate, alcohol, firearms, or tobacco) content audit standard; and ■ Additional compliant program samples in Appendix A and in Appendix B.
1.7	March 27, 2017	The CTIA Short Code Monitoring Handbook was updated with the following: • Version history for handbook updates; • STOP keyword for recurring-message advertisements update; • Positioning of the terms and conditions disclosure update;

VERSION HISTORY1

INTRODUCTION

CTIA and its member companies work to protect consumers while fostering a competitive environment for short

code programs. We aim to

■ Provide consumers the best possible user experience;

■ Honor consumer choices and prevent abuse of messaging platforms;

■ Deliver flexible guidelines that communicate compliance values clearly;

■ Enable the short code industry to self-regulate; and

■ Facilitate enforcement measures, if necessary, to protect consumers quickly and consistently.

The Short Code Compliance Handbook (Handbook) guidelines lay the framework for achieving these goals, but

CTIA reserves the right to take action against any short code program deemed to cause consumer harm.

The Handbook is not intended as a comprehensive guide to compliance with laws and regulations that apply to

short code programs. Service providers are responsible for meeting legal requirements that apply to short code

programs they offer, and CTIA and its members make no representation that meeting the guidelines in this

Handbook is sufficient to assure legal compliance. Consultation with legal counsel is recommended strongly.

ABOUT THIS HANDBOOK

This Handbook describes best practices for standard rate messaging services (SMS), multimedia messaging

services (MMS), and free-to-end-user (FTEU) short code programs with the primary goal of providing the best

customer experience for users. Handbook guidelines do not define rules for programs that bill consumers.

Guidelines are organized according to use cases that apply. Examples of compliant programs are organized by

use case in the appendices.

Carriers reserve the right to implement their own short code program requirements beyond the scope of this

Handbook. However, all carriers have reviewed and accepted the Handbook’s content.

This Handbook is divided into the following sections: Compliance Framework, In-Market Monitoring Guide, Audit

Standards Guide, and Audit Standards. In addition, Appendix A and Appendix B detail sample compliant

programs, and Appendix C describes common terms.

REFERENCES

Drawing from experience working with short code programs, the guidelines evolve continually. Handbook vl .7 is

based on the following:

■ Mobile Marketing Association’s Consumer Best Practices v7.0,

■ CTIA Mobile Compliance Assurance Handbook vl .3,

■ California Attorney General Kamala D. Harris’s “Privacy on the Go: Recommendations for the Mobile

Ecosystem” best practices,

■ Telephone Consumer Protection Act (TCPA),2

■ Florida Attorney General’s requirements for mobile content,

■ A2P (application-to-person) community feedback, and

■ Carrier requirements.

2 http://www.qpo.gov/fdsvs/pkq/USCODE-2011-title47/pdf/USCODE-2Q11-title47-chap5-subchapll.pdf

COMPLIANCE FRAMEWORK

This section offers direction regarding compliance of short code programs, including guidelines and requirements.

Nonetheless, following this handbook is no guarantee that a short code program is compliant. Short code

programs might also need to comply with individual carrier requirements.

UNIVERSAL COMPLIANCE PRINCIPLES

CTIA requires all short code programs to comply with a basic code of conduct that promotes the best possible

user experience. As new uses for short codes emerge, the guiding principles in section A.1 should be considered

when defining applicable rules. Short code programs that comply technically with the letter of a specific rule but

violate the letter or spirit of these principles might be subject to enforcement action.

A.1 GUIDING PRINCIPLES

Four principles provide the baseline for all requirements listed below:

Displayclear calls-to-action. All programs must display a clear call-to-action. Customers must be made

aware of what exactly they are signing up to receive.

Offerclear opt-in mechanisms. Customers must consent clearly to opt into all recurring-messages

programs. Requiring a customer to enter a mobile phone number does not constitute a compliant opt-in.

Instead, customers must understand they will receive messages and consent to receive them.

Sendopt-in confirmation messages. A confirmation message must be sent to customers always. For

recurring-messages programs, confirmation messages must include clear opt-out instructions.

Acknowledgeopt-out requests. Short code service providers must acknowledge and act on all opt-out

requests. Monitoring procedures confirm successful opt-out.

A.2 CHOICE AND CONSENT

Short code programs are expected to deliver sufficient value so consumers elect to participate with full

transparency into the delivery conditions.

A.2.01 UNSOLICITED MESSAGES

Unsolicited messages may not be transmitted using short codes. Unsolicited messages are defined as follows:

■ Messages delivered without prior express consent from the user or account holder, and

■ Messages sent after a user has opted out.

A.2.02 MARKETING CONTEXT

No component of program advertising or messaging may be deceptive about the underlying program’s

functionality, features, or content. All disclosures present in pre-purchase calls-to-action, advertisements, terms

and conditions, and messages must remain clear and consistent throughout the user experience.

A.2.03 OPT-IN

Messages must be delivered to a consumer’s mobile device only after the user has opted in to receive them. A

user might indicate interest in a program in several ways. For example, a user might

■ Enter a phone number online,

■ Click a button on a mobile webpage,

■ Send an MO message containing an advertising keyword,

3 Sending the user a single opt-out message acknowledging the opt-out request is the only exception to this rule.

■ Sign up at a point-of-sale (POS) location, or

■ Opt in over the phone using interactive voice response (IVR) technology.

Calls-to-action must be clear and accurate; consent must not be obtained through deceptive means. For example,

opt-in details cannot be displayed obscurely in terms and conditions related to other services. Enrolling a user in

multiple short code programs based on a single opt-in is prohibited, even when all programs operate on the same

short code.

Recurring-messages short code programs should send a single opt-in confirmation message that displays

information verifying the customer’s enrollment in the identified program. The opt-in confirmation message must

be delivered immediately after the customer opts into the program. For POS and hardcopy opt-ins, the opt-in

confirmation message must be delivered as soon as is reasonably possible after the customer opts into the

program. Additionally, opt-in messages must contain the program (brand) name or product description, customer

care contact information, opt-out instructions, product quantity or recurring-messages program disclosure, and the

“message and data rates may apply” disclosure.

The opt-in for all short code programs must comply with all legal and regulatory requirements, including the

Telephone Consumer Protection Act, 47 U.S.C. § 227, and the Federal Communication Commission’s rules under

47 C.F.R. § 64.1200. For example, the express written consent obtained for any program that is “telemarketing”

[as defined by 47 C.F.R. § 64.1200(f)(14)] must, unless exempt from the requirement, include the elements of

“prior express written consent” set forth in 47 C.F.R. § 64.1200(f)(8). That rule requires a clear and conspicuous

disclosure informing the user that:

■ By opting in, the user authorizes the seller to deliver or cause to be delivered to the user marketing

messages using an automatic telephone dialing system; and

■ The user is not required to opt in (directly or indirectly) as a condition of purchasing any property, goods,

or services.

Legacy double opt-in (i.e., mobile device confirmation) methods remain acceptable options to obtain express

consumer consent.

A.2.04 OPT-OUT