Leveraging Campaign Verify and other industry standards to navigate the sometimes-confusing SMS environment in the United States

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The 2022 US mid-term election season is now well underway where candidates across the United States will be vying for local, state, and national elections. 

Over the last decade, texting has become a key channel for political candidates, as well as PACs, committees, and other political organizations to reach constituents, voters, donors, volunteers and more. Now, more than ever, mobile messaging is playing a central role in spending campaign funds, as our economy is now, more than ever, mobile centric.  The 2020 US presidential elections resulted in over 2.126 billion political text messages through 20 November 2020, per statistics from RoboKiller. And why not?  With open rates around 95%, text messaging has always been a key channel for businesses and brands to reach consumers.  Political campaigns and related organizations want to leverage this type of efficacy as much as possible. 

But so do spammers and nefarious actors.  And herein lies the problem.   

SMS or text messaging spam has been a concern of mobile operators since the beginning of text messaging.  To date, SMS has been a relatively spam-free medium.  I say, “spam-free” as it has nowhere near the level of spam that email has; however, not for the lack of trying.  Each month, hundreds of millions of spam messages are blocked by mobile carriers and third parties on their behalf.  This has worked to stem the flow of spam considerably. Certainly, some get through.  We’ve all seen it: phishing attacks, non-solicited adult spam, scams, and yes, political texts. 

The messaging industry has worked diligently to suppress spam, but to also encourage businesses, brands, and other organizations to use SMS to reach consumers.  But there are rules and regulations as well as best practices that have been put into place to filter out the bad actors, but still enable and encourage commercial and non-profit/political texts.   

The 10-digit long code or regular phone number as an SMS sender ID has only been approved by US carriers for a short time.  10DLCs (for 10-Digit Long Codes – e.g., regular telephone numbers) as they are called, had been used as sender phone numbers for business texting for years before they were officially sanctioned.  Now they are, and the US carriers have worked with other messaging industry players to sanction 10DLCs as sender IDs.   

Businesses that wish to use 10DLC also register their messaging campaigns with an organization called The Campaign Registry.  All major US carriers are participating in TCR for 10DLCs.  Part of that process is that some level of vetting is done to determine the trustworthiness of an organization. Once the vetting is complete, the messaging campaign is ready to go live, fully sanctioned by the wireless carriers.  This is important, as approved 10DLC SMS (and MMS for that matter) traffic is not subject to spam filtering before the messages reach the end consumers. 

For political campaigns (note: a different usage of the word “campaign” than in the previous paragraph), ideally, the same rules apply. Now, for political messaging, there is the concept of Peer-to-Peer Messaging (or P2P messaging), which really came into usage in the 2016 Presidential campaign and has grown considerably since that time. Originally, Peer-to-Peer Messaging used the Person-to-Person SMS ecosystem. While that’s a bit confusing, we should note that in the US, and around the world – there are really two messaging ecosystems:

• The Person-to-Person (also called P2P) ecosystem which is one person texting another – either to another subscriber of the same mobile operator or another subscriber who uses another mobile operator (e.g., Verizon subscriber to Verizon subscriber OR Verizon subscriber to T-Mobile subscriber, etc.) 

• The Application-to-Person (called A2P) ecosystem, which is typically a business texting a subscriber, but also includes subscribers texting businesses, conversations between subscribers & businesses – basically anything that is not P2P.  Before 10DLCs were sanctioned, the only officially sanctioned method to send business texts was to use short codes (5- or 6-digit identifiers).  Mobile carriers typically charge small fees for a business message to be delivered to one of their subscribers. That is paid by the business / organization / brand to either Messaging Service Provider (who will pass through the carrier fees) or directly to a carrier. 

Now we have a fully sanctioned 10DLC ecosystem for A2P messaging.  While the Peer-to-Peer messaging concept is still alive and well, it does have some dubious distinctions that it is not truly person-to-person.  In fact, we see that many subscribers have complained that they have not opted-in to receive these political texts – even though they seem as if from an individual.  To that end, Peer-to-Peer messaging over the person-to-person ecosystem is increasingly being targeted as spam by mobile operators, as their subscribers complain that they did not opt-in for these messages.  But many messaging organizations are leveraging established, compliant 10DLC routes for peer-to-peer messaging, which is fully sanctioned by the carriers, once the sending organization has been fully vetted and approved.

An April 2021 article in The Intercept_ has noted that some progressive groups are concerned that 10DLC rules may negatively affect them as mobile operators and the messaging industry increasingly move to the fully sanctioned 10DLC ecosystem, which would include Peer-to-Peer messaging. They also point to the not-for-profit vetting group called Campaign Verify as potentially having some conflicts of interest.

Campaign Verify promotes itself as “a non-partisan, nonprofit service for U.S. political campaigns, parties, and PACs to verify their identity.”  In other words, Campaign Verify is a vetting service especially for political messaging and will play a key role in the success for the messaging channel. By completing Campaign Verify vetting, political candidates or organizations can leverage the benefits of using regular phone numbers or 10DLCs as sender IDs for their mobile messaging outreach. All of this is to help protect consumers from spoofed and/or non-compliant, unapproved messaging. We should also note that all conflict of interest issues that were called out in The Intercept article have long been resolved.

To be fully sanctioned, organizations that wish to leverage 10DLCs as the sender IDs for their messages, must register their organization with The Campaign Registry (TCR).  If you view the vetting partners listed in TCR, you will note that one of the vetting organizations is Campaign Verify.  Again, this is specifically for political entities that file with a Federal, State, Local, or Tribal election authority.  All 527 political organizations will need to register with Campaign Verify. The cost to the political organization is $95 for the verification request and one successful verification request is required per two-year election cycle.  This means that verifications submitted in 2021 or 2022 will be valid until January 31, 2023. 

Each political campaign or organization will have to provide information to Campaign Verify as follows: 

For Federal Verification: 

• The official filing name of the organization 
• FEC filing URL – this is the link to the official filing page for the committee on the FEC’s website 
• Email address – this should match the official email address on the FEC filing document 
• Street Address, City, State, Zip – to match the FEC filing document 
• FEC Committee ID 

• Verification preference – either email or postal mail to receive the PIN code generated by Campaign Verify 
• Committee Type – this is a pull-down list that will be covered below 

For State, Local or Tribal Verification: 

• The official filing name of the organization – e.g., legal name of the committee 
• Filing record URL – link to an online record of the committee or campaign filing 

• Section of State, Local, or Tribal 
• State, District or Territory where the committee is filed 
• Committee EIN or Social Security Number if an EIN is not available 
• Committee Website URL 
• Email address – this should match the official email address on the filing record 

• Street Address, City, State, Zip – to match the filing record 
• FEC Committee ID 
• Verification preference – either email or postal mail to receive the PIN code generated by Campaign Verify 
• Committee Type – this is a pull-down list that will be covered below 

Each organization will need to designate what type of committee they are.  There is a pull-down during the registration process that designates one of the 12 committee types.  In all cases, the organization will be providing a URL to the appropriate public record, which will aid in the vetting process. 

Once all the information is submitted, the organization will receive a secret PIN code (either by email or postal mail).  That PIN code may be used to then enter the Campaign Verify site to generate a secure token that the organization can then provide to the messaging provider (such as Sinch).  If 10DLCs will be used as SMS/MMS sender IDs, then this token will then be used as part of TCR registration that confirms that the organization is a legitimate political campaign or organization.   

Organizations that complete Campaign Verify vetting and then complete their registration on TCR will have a high trust score and this will enable them to send more daily messages, among other benefits from the carrier networks. 

If the political organization intends to use a short code or codes as a sender ID, the organization does not yet have to register with Campaign Verify, but it wouldn’t hurt.  This may become a requirement in the future.  That way, if the organization wants to use 10DLCs as sender IDs, they are already registered and have the token for The Campaign Registry. 

We should note at this point that Campaign Verify is very much agnostic to the sender ID (10DLC, short code, toll-free, etc.) as well as the type of messaging channel (SMS or MMS) or how messages are sent (through traditional A2P methods vs. peer-to-peer).  Campaign Verify does not have any visibility as to whether the organization uses the appropriate opt-in mechanisms. Some of that will be attested to within TCR. 

Regardless of how messages are sent by organizations, users should have been able to explicitly opt-in to receive these messages.  A simple list of voters, does not an opt-in list, make!  Organizations need to err on the side of caution regarding user opt-ins.   

While the FCC recently ruled that Peer-to-Peer texting was not considered an Automatic Telephone Dialing System (ATDS) under TCPA rules (this means they won’t be sued on TCPA rules), we should note that the US carriers still consider Peer-to-Peer texting, especially without opt-in, as quite troublesome. This is because many subscribers complain that they are receiving political (and other) messages that they did not opt-in for.  Consequently, even if Peer-to-Peer texting is being used by a political organization, we recommend that organization register with Campaign Verify and The Campaign Registry and institute an opt-in policy. Otherwise, unregistered 10DLCs used for Peer-to-Peer traffic may be blocked as spam within the ecosystem. 

Overall, the text messaging ecosystem is quite secure, with only a small percentage of spam getting through.  This is due to increased vigilance by carriers, by messaging providers, and through the establishment of Messaging Principles and Best Practices from the CTIA which helped codify 10-Digit long codes as an acceptable and sanctioned sender ID, in addition to short codes for non-personal (or P2P traffic).  The Campaign Registry (TCR) was designed specifically to manage 10DLC A2P messaging and Campaign Verify was established specifically as an unbiased agency to register organizations for political texting.  If political organizations follow these best practices, they can easily enjoy the outstanding open rates that SMS provides, and are able to reach voters, donors, and volunteers quickly and effectively.