COMEXCEL 10DLC & Business Messaging Policy

Purpose, Scope & Governing Ecosystem

This policy governs all SMS, MMS, and A2P messaging sent over COMEXCEL telephone numbers, SIP gateways, mobile applications, desktop softphones, CRM integrations, and developer REST APIs. Compliance with this policy is mandatory and constitutes a legally binding addendum to the COMEXCEL Terms of Service. It enforces statutory compliance under:

• The Telephone Consumer Protection Act (TCPA) and FCC regulatory rulings.
• CTIA Short Code and Commercial Messaging Best Practices.
• Major Tier-1 Mobile Network Operator (MNO) policies (AT&T, Verizon, T-Mobile).
• The Campaign Registry (TCR) brand and campaign standards.

Contextual Link: Comexcel Terms of Service

Targeting URL: https://comexcel.com/legal/terms-of-service/

Understanding A2P 10DLC Architecture

Application-to-Person 10-Digit Long Code (A2P 10DLC) refers to business messaging sent across standard local phone numbers to mobile subscribers. To protect consumers from spam and ensure high delivery rates, wireless carriers require all business traffic to route through verified identity registries:

[Business Entity] ➔ [COMEXCEL Platform] ➔ [The Campaign Registry (TCR)] ➔ [Carrier Gateway] ➔ [Recipient Device]

Unregistered traffic is subject to severe carrier throttling, aggressive content filtering, message blocking, and punitive per-message non-registration surcharges.

10DLC Brand & Campaign Registration Requirements

Customers must register their legal corporate brand and individual messaging campaigns prior to sending production traffic:

• Brand Verification: Submission of legal corporate name, Employer Identification Number (EIN) or Tax ID, Dun & Bradstreet data, corporate address, entity type, and executive contact details.
• Campaign Description & Use Case: Explicitly detailing the purpose of the campaign (e.g., Customer Care, Account Alerts, 2FA/Security, Marketing).
• Call-to-Action (CTA) / Opt-In Workflow: Documenting the exact mechanism used to obtain consumer consent, including live website URLs, registration screenshots, and disclosure wording.
• Sample Messages: Providing representative message templates showing exact sender branding, message copy, and required opt-out disclosures (Reply STOP to cancel).
• Privacy Policy & Terms Compliance: Maintaining an accessible COMEXCEL Privacy Policy-compliant website disclosure containing an explicit non-sharing clause for mobile data.

Consent Framework: Conversational, Informational & Promotional

Customers must obtain the requisite tier of consent before initiating SMS/MMS communications:

Compliant Web Forms, Point-of-Sale & Opt-In Capture

When capturing mobile consent through digital web forms, checkout portals, or paper intake forms:

• Unchecked Checkboxes: The SMS consent checkbox must be separate from general terms of service and unchecked by default. Pre-checked boxes are strictly invalid under CTIA rules.
• Required Legal Disclosures: The opt-in form must visibly display the business brand name, expected message frequency, carrier rate disclaimers, and direct links to your Privacy Policy and Terms.

Compliant Web Form Disclosure Text:

“By checking this box and providing your phone number, you agree to receive recurring automated promotional and informational text messages from [Business Name] at the number provided. Consent is not a condition of purchase. Msg frequency varies. Msg & data rates may apply. Reply STOP to cancel or HELP for help. View Privacy Policy and Terms.”

Verifiable Opt-In Recordkeeping & Non-Transferability

Customers must maintain complete, audit-ready records of consumer consent for a minimum of 4 years. Records must document:

• Recipient phone number and exact timestamp.
• Opt-in source URL, physical intake form, or point-of-sale receipt.
• Exact version of the disclosure text presented to the consumer.
• Non-Transferability: Opt-in consent applies solely to the specific brand and use case for which it was collected; consent cannot be shared, assigned, rented, or transferred to subsidiary brands or third parties, consistent with our COMEXCEL Privacy Policy non-disclosure standards.

Zero Tolerance for Purchased, Rented & Scraped Lists

COMEXCEL strictly prohibits transmitting messages to contact lists that have been purchased, rented, co-registered, web-scraped, or acquired from third-party lead brokers. Having a consumer’s phone number does not establish consent; messages sent without direct, first-party authorization violate carrier policies and result in immediate route termination.

Sender Transparency & Initial Welcome Messages

Every message sent across the COMEXCEL network must clearly identify the originating business within the body copy. The first message sent in any automated or marketing campaign must include:

• Business/Brand Name.
• Purpose of the messaging program.
• Message frequency disclaimer (“Msg frequency varies”).
• Carrier rate disclaimer (“Msg & data rates may apply”).
• Clear instructions for assistance (“Reply HELP for help”) and opt-out (“Reply STOP to cancel”).

Automated Opt-Out (STOP), HELP & Universal Keyword Handling

The COMEXCEL network enforces automated keyword processing at the carrier gateway layer:

• Universal Opt-Out Keywords: Inbound messages containing STOP, END, CANCEL, QUIT, UNSUBSCRIBE, or ARRET trigger immediate automated suppression across the campaign.
• FCC Revocation Standard: In compliance with FCC rulings, opt-outs submitted by any other reasonable method (email, phone call, customer portal) must be manually suppressed in your CRM within 24 hours.
• HELP Keyword Workflow: Inbound messages containing HELP or INFO return an automated support message detailing brand name, customer support contact details, and opt-out instructions.

Opt-Out Confirmation & Affirmative Re-Opt-In (START)

• Single Confirmation Text: Upon receiving a valid opt-out keyword, the platform returns a single neutral receipt: “[Business Name]: You have been unsubscribed and will receive no further messages. Reply START to resubscribe.” No promotional copy or survey links may appear in this text.
• Handset-Initiated Re-Opt-In: A previously unsubscribed contact can only re-join a campaign by sending START, YES, or UNSTOP directly from their mobile handset. Businesses cannot manually clear suppression flags on behalf of a contact.

CRM Integrations, Webhooks & Automated Workflow Safeguards

When linking COMEXCEL with CRM platforms (Salesforce, HubSpot, Zoho), webhooks, or custom REST APIs:

• Pre-Send Consent Check: Automated workflows must check customer consent records and active suppression lists prior to dispatching SMS payloads.
• Rate-Limit Safeguards: Automated triggers must respect per-second throughput quotas to avoid carrier flood filters.
• Human Hand-Off: Automated conversational AI agents must provide a clear path for recipients to request live human agent assistance. Security requirements governing API endpoints are detailed in our Security & Trust Center.

Production Message Templates & Content Formatting

All message templates must adhere to standard character constraints and clear business formatting:

• Transactional / Appointment Reminder Template:

[Business Name]: Hi [First Name], your appointment is confirmed for [Date] at [Time]. Reply C to confirm or call [Phone Number] to reschedule. Reply STOP to cancel.

• Customer Support Follow-Up Template:

[Business Name]: Hi [First Name], this is [Agent Name] following up on support ticket #[Ticket Number]. Let us know if you need further help! Reply STOP to opt out.

• Promotional / Marketing Offer Template:

[Business Name]: Enjoy [Discount Offer] on your next order with code [CODE] at [Branded URL]. Msg frequency varies. Msg & data rates may apply. Reply STOP to cancel.

Prohibited Content, CTIA SHAFT & High-Risk Niches

All message transmissions are subject to the prohibited traffic and anti-abuse standards outlined in the COMEXCEL Acceptable Use Policy. Carrier firewalls strictly block:

• CTIA SHAFT Topics: Sexually explicit material, Hate speech, Alcohol (unless registered under strict carrier-approved age-gating programs), Firearms, and Tobacco/Vapor/Cannabis/CBD/Delta-8 products.
• High-Risk Financial Services: Payday loans, cash advances, debt consolidation, debt relief, credit repair, cryptocurrency schemes, and deceptive lead generation.
• Deceptive Practices: Phishing, smishing, social engineering, impersonation, sweepstakes, and unverified multi-level marketing (MLM) programs.

URL Shorteners, Branded Domains & Hyperlink Integrity

• Public Link Shorteners Prohibited: Generic, shared link shorteners (e.g., bit.ly, tinyurl, rb.gy) are heavily blocked by Tier-1 carrier filters.
• Dedicated Branded Domains: Senders must use full URLs or dedicated, branded custom domain shorteners (e.g., [link.yourbrand.com/offer](https://link.yourbrand.com/offer)) where the domain matches the verified 10DLC brand registration.
• No Redirect Chains: Links must direct immediately to the destination landing page without multi-hop affiliate redirect chains.

Throughput Limits, Volume Tiers & Anti-Snowshoeing Rules

• Throughput Allocations: Campaign throughput (Messages Per Second / Daily Volume) is determined dynamically by The Campaign Registry (TCR) vetting scores and carrier trust tiers.
• Anti-Snowshoeing Ban: Distributing identical messaging volume across dozens of unregistered or rotational phone numbers to evade carrier throughput caps or spam filters is strictly prohibited. Senders must use designated high-throughput 10DLC or Toll-Free campaign routes backed by automated Failover & Disaster Recovery path management.

Carrier Filtering, Message Delivery & Downstream Liability

Customers acknowledge that mobile carriers (AT&T, Verizon, T-Mobile) operate dynamic, proprietary spam-filtering firewalls. COMEXCEL is not liable for messages throttled, filtered, or blocked by downstream carriers due to non-compliant templates, high opt-out ratios, or unverified campaign traffic.

Carrier Fines, Pass-Through Surcharges & Enforcement

Standard carrier network access surcharges for outbound and inbound SMS/MMS are billed directly to customer accounts. Severe compliance breaches carry direct pass-through fines assessed by Tier-1 carriers: