100% agree here. This is cartel / monopoly behavior and should be attacked as such.

The facts as I understand them are:

1. All API originated traffic is considered A2P regardless of if its an
   app with a physical single person thumbing in messages at the far
   end. API involved = A2P. Done (lets ignore the fact that iMessage
   and Android messaging are now API as well)
2. This means all non MNO traffic is A2P and subject to the fees
3. If my customers who are single/small users, cancelled my service and
   signed up for VZW they would get the same service (actually much
   less) but not have to deal with this (this is the sort of antitrust
   behavior Microsoft has been sued for and lost multiple times over).
4. TCR is in effect levying a tax, but is a private entity, whose
   proceeds and use thereof are not public record. Honestly I cannot
   figure out what the cost justification for the whole thing really is
   or how they arrived at the pricing.

Are we complying? Yes because the average customer simply doesn't / wont care why their messages aren't going through and presume you are at fault / incompetent. This isn't the hill I am going to pick to die on.

What we are doing is passing this through nearly 100% with links on our invoices to a page explaining why this is happening. This gives us to the penny accounting as well as we are quite keen to join any class-action suit on the topic. I may start one if I can find counsel and enough to join in.

We can all thank Ajit Pai for this. SMS is a telecom service not a data service. There is no longer a differentiation, data = telecom today.

-Ryan

On 11/29/2021 11:30 AM, Carlos Alvarez wrote:
Alarmist is warranted.  I am equally perplexed by the inconsistent rules, the vague language, and by everyone insisting that T-Mobile will unilaterally issue $10k fines per message.  On what authority?  What is the appeals process? Dozens of questions, nearly no answers.

I just sent a text from one of my business numbers in response to a client who texted it.  Is this a campaign?

The whole thing where everything that's not another cell phone is considered automated and not P2P seems disgusting, if not actually illegal and fraudulent.


On Tue, Nov 16, 2021 at 4:16 PM Oren Yehezkely <oren...@gmail.com> wrote:

    Nate,

    See a thread I started a few months ago about this matter.
    I got a lot of negative responses for being an alarmist.

    Basically these requirements are set by the different mobile
    carriers and they are not the same.

    Yes, they all consider customers to be businesses (A2P). No
    customer is a consumer (P2P) in the eyes of these
    carriers, TCR and even the person who answered you before.

    I don't think that the penalty is $10,000 but VI may be trying to
    deter you from using SMS
    without registering. You may want to consider using a different
    carrier for SMS.
    Other carriers will also offer to help you register with TCR.

    Good luck with dealing with that headache, feel free to contact me
    off list to see if we can share some information
    on dealing with this.

    Regards,
    Oren

    On Mon, Nov 15, 2021 at 3:37 PM Nate Burke <n...@blastcomm.com> wrote:

        Sorry if this was already discussed and I missed it.  I saw a
        notice on
        our Voip Innovations account today that any business DID's
        that send SMS
        messages to a consumer in any way now have to be registered with
        'Campaignregistry.com'  Looks like this requires a $200
        signup, and then
        potentially $10/month/DID.  Anyone already gone through this? 
        Talking
        to VI, it seems they're not even sure, but it's a VI
        requirement to be
        registered by Dec 15.

        The whole process seems confusing.  VI Makes it seem like
        non-compliance
        will be expensive. $10,000/violation keeps being referenced.

        Would each one of my customers be considered a separate
        campaign at
        $10/month?
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