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Stopping Illegal Robocalls Where They Start

Learning Lessons from Text Messaging

For those of us focused on nefarious VOICE calling, it might be worth a brief look at the texting world – officially called Short Messaging Service, or SMS.

Voice calls and texts are cousins because they both make use of telephone numbers. In the United States, this is the North American Numbering Plan. Most of us are used to sending and receiving texts from our mobile phones.

Providers have historically been protective of messaging capability. For some time, they have distinguished between what they call P2P messages – conventional person-to-person texts originated by one subscriber and delivered to another, in contrast to A2P messages, which are originated by an application (computer system) and directed to an end-user.

For many years, the industry has supported Short Codes for mass messaging. These are 4-, 5-, or 6-digit codes for which companies register and pay, then use to send A2P messages. The codes are also capable of receiving messages. But short codes cannot receive voice calls because they are not dialable numbers.

To overcome that constraint, A2P senders started originating their calls from regular (10-digit) telephone numbers (called 10DLC, for 10-digit long code), so recipients could call them back.

Some bad actors started sending messages from numbers they did not own (spoofing). We were on the cusp of corrupting the messaging network to a degree similar to what we have seen in voice.

Providers know that A2P messaging can be quite dangerous, just like dialer traffic in the voice world. To protect messaging integrity, providers now are:

  • Segregating messaging flows, so that P2P and A2P traffic are kept distinct.
  • Establishing specific rules and a protocol to be followed when sending A2P messages.
  • Monitoring P2P traffic to ensure that it is not polluted with automatically-generated messages.

To make sure everybody follows their rules, the providers have:

  • Set up com, where A2P senders must register their campaigns before sending messages; an impressive list of providers have signed on.
  • Imposed significant fines for failing to follow the rules.

Fines are important because monetary deterrents are most effective in stopping (and preventing) bad behavior. Here are a few examples of the fines that T-Mobile says they will impose for failure to follow their extensive Code of Conduct:

  • Text Enablement: A $10,000 fee if T-Mobile receives a complaint that traffic is being sent using a phone number that the sender does not have authorization to text enable.
  • 10DLC Long Code Messaging Program Evasion: A $1,000 fee if a program is found to use techniques such as snowshoeing, dynamic routing, or unauthorized number replacement.
  • Content Violation: A $10,000 fee for each unique instance of the third or any subsequent notification of content violating the T-Mobile Code of Conduct involving the same content provider. This includes SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco) violations, spam, phishing, and messaging that meets the Severity 0 violation threshold per the CTIA Short Code Monitoring Handbook.
  • Grey Route: A $10 per message fee if A2P messages are sent over P2P routes.

If this fee is assessed on the provider that sent the message(s) in violation, that provider will no doubt pass it back to their customer.

Compared to the voice world, the messaging ecosystem enjoys some advantages in keeping all the players in line:

  • Messages go more directly from an originating provider to the terminating provider. Voice calls can hop through numerous providers to get to their destination, making the originator harder to find.
  • Messages include the CONTENT of the message (of course), in addition to the originating and terminating phone numbers. Voice call signaling is distinct from the content (audio), making it much harder to know the nature of the call and determine compliance with rules.
  • Billing systems are less convoluted in the messaging world, making it easier to impose fines.

Text messaging is not problem-free, but it is faring better than voice. Those of us in the voice world should be able to find some good ideas buried here that we can adapt.

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