TCPA list validation

The Telephone Consumer Protection Act (TCPA) list validation helps you follow the US market regulations and stay compliant when running SMS and MMS campaigns. It automatically excludes litigators from your SMS and MMS marketing program. It helps you avoid sending text messages to deactivated phone numbers. It also ensures you don't send marketing text messages to customers whose phone numbers were reassigned.

The TCPA is the primary federal law governing the regulation of telephone solicitations in the US market. Read more about TCPA and CTIA compliance in the US market.

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Important

To start using it, you must assign at least one consent category within the TCPA list validation settings.

What the feature does

TCPA List Validation consists of 2 separate parts:

• Scrub against do not call (DNC) list.
• Check against the reassigned phone numbers database.

Check frequency

2 types of TCPA checks happen.

1. The first check is done every 15 days. If you want to change the time period to do more checks, contact your Account Manager. By law, the required period is every 31 days.
2. The second check is done daily.

Scrub against the DNC List

It helps you scrub your database of phone numbers against the DNC registry to detect potential litigators infiltrated between your subscribers. Then, it disallows them from receiving your marketing text messages right after they are marked as litigators.

The result of the TCPA check is stored as the tcpa_check_result customer attribute. If the scrub identifies the phone number as a litigator (tracked as tcpa_check_result=Litigator), such phone numbers will be ignored during the execution of the SMS and MMS campaigns. Bloomreach Engagement will also automatically track this number as an invalid_contact event. This prevents any further SMS or MMS campaigns for this customer.

There might be other possible results for the TCPA scrub check than litigators. Engagement doesn't exclude these customers from SMS or MMS campaigns. You decide if their consent was collected by TCPA and CTIA regulations and guidelines.

If yes, these customers can still receive the SMS and MMS campaigns. If not, our recommendation is to filter them out of the campaign.

Examples of different TCPA check results:

• tcpa_check_result=National (USA) 2021-01-01
• tcpa_check_result=National (USA) 2021-01-01;State (TX) 2022-01-01

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Important

You can store up to 255 customer properties. After you reach the storage limit any tracking that contains new customer attributes will be discarded (including tcpa_check_result) which will lead to the malfunction of the TCPA List Validation check.

Example of the customer profile after the positive litigator identification:

Example of the invalid_contact event tracked under customer profile:

Check against the reassigned numbers database

It helps you to identify deactivated or swapped numbers that are automatically opted out of your SMS marketing program. It is usually done within 24 hours of deactivation.

It checks against the reassigned phone numbers database. If the check identifies such a number, the consent for a customer is rejected automatically. Consent rejection ensures that no further SMS and MMS campaigns are sent out to the customer. The customer can be contacted only after they subscribe to the SMS or MMS again. These checks run on a daily basis and check only US and CAN numbers.

Each consent rejection (consent event with event attribute action=reject) also contains additional information about the number of deactivations or swaps (event attribute message=TCPA reassigned number database: The phone number was deactivated or message=TCPA reassigned number database: The phone number was swapped).

Example of the consent event tracked for a deactivated phone number:

Configuration settings

TCPA list validation is available as a separate account module. It is disabled by default and needs to be enabled by the CSM. Once the account module is enabled, you can configure the TCPA List Validation via the Project settings > Campaigns > Channels > SMS / MMS / RCS.

Use cases

• Automatically remove reassigned or deactivated numbers and litigators from your send list to ensure TCPA compliance.
• Segment the users who changed carriers and request their consent again.
• Update user consent and preferences in real time, excluding users who don't want to be contacted.
• Strengthen your brand’s bond with customers by respecting their preferences and favorite communication channels.