Toll-Free numbers have been a staple of consumer and business communications for nearly 50 years. The promise of Toll-Free communication is clear: when calling a Toll-Free Number, an order gets taken, questions get answered, problems get solved, consumers’ pleas for help get heard.

Today, more than 40 million Toll-Free numbers are used by businesses and organizations providing a recognizable way for consumers to connect with them. Toll-Free numbers are used to route millions of calls daily across sales centers and help desks around the world and to track the effectiveness of major marketing campaigns. Simply put, Toll-Free means business.

What enables all this coordination is a registry database – a single, accurate, and active record of which entity has reserved a given Toll-Free number, along with the routing information needed to complete calls accurately. This trusted, neutral registry for Toll-Free numbers is what maintains the order and reliability on which consumers and businesses depend.

In response to recent changes in market demands and evolutions in technology, Toll-Free has evolved from voice-only to a service across multimedia platforms, including text messaging. Today, consumers often prefer texting over voice calls for common transactions such as making a reservation, scheduling an appointment, or inquiring about a product or service. For businesses, texting to Toll-Free numbers is now a key part of marketing and branding strategies with click-to-text options increasingly being used in online advertising. This creates greater ease of interaction for consumers and new opportunities for businesses to better understand their customers’ needs.

As with traditional Toll-Free voice services, order and a level playing field are essential to ensuring the texting to Toll-Free system remains dependable and safe. In order to protect consumers and guard against anti-competitive behavior, in 2014, CTIA brought together key members of both the messaging and Toll-Free communities to develop new guidelines.  This partnership led to the creation of the TSS registry for Toll-Free messaging services.  

The TSS Registry maintains the authoritative routing and service provider data for all text-enabled Toll-Free numbers, validates Toll-Free numbers as working for text enablement requests, and notifies the organization controlling the number of the request.

Unfortunately, not everyone in the messaging ecosystem is following CTIA’s guidelines which is causing uncertainty and chaos in the industry and, increasingly, consumer harm. Ignoring proper validation and controls for text-enabling Toll-Free numbers now has consumers unwittingly engaging with fraudulent companies and becoming vulnerable to identity theft when personal information is shared.  When Toll-Free numbers are not text-enabled in an orderly fashion, business reputations are being harmed leading to lost revenue and customers.

Ignoring industry guidelines for text-enabling Toll-Free numbers may soon put our safety at risk. When there isn’t a clear, reliable way to quickly find the network provider of a Toll-Free number from a fully reliable source, law enforcement becomes more difficult, and the public safety might be jeopardized.

This situation has evolved, in part, because the major wireless carriers treat texting to Toll-Free numbers differently than all other messaging traffic (i.e., mobile to mobile, mobile to landline, or mobile to short code). Instead of using customary and competitive channels, they segregate all text messages to Toll-Free numbers and route them to a single aggregator.  This entity – which does not have a parallel in non-Toll-Free messaging – not only controls the flow of texting traffic to and from Toll-Free numbers, but also competes on a retail level with Toll-Free messaging service providers by selling texting services to Toll-Free end-users.  

As a result of the anti-competitive positioning of the wireless carriers’ chosen aggregator, other retail service providers of Toll-Free messaging services are being disadvantaged. They have had their messaging traffic shut off without notice or purpose, and their cost of providing services has skyrocketed from the lack of competitive choices. 

This aggregator is the same party that does not follow the CTIA guidelines for text enablement of Toll-Free numbers. The industry can’t grow and flourish as long as one party controlling all the traffic dictates the rules and pricing to the rest of the industry while also ignoring industry guidelines. 

Without the confidence to trust the texting to Toll-Free ecosystem, businesses are putting new innovations on hold and are unable to move their communication strategies and technologies forward. In order to realize the true promise of the Toll-Free system and ensure it can keep pace with modern technological advances, we need a marketplace that encourages, not stifles, innovation.

During the past five decades, Toll-Free has played a significant role in how Americans do business. Industry coordination and cooperation has made Toll-Free the reliable way for consumers and businesses to communicate. While the industry collectively agreed to a self-regulatory system to manage the texting to Toll-Free ecosystem, the entity charged with overseeing that self-regulation – CTIA – needs to step up and hold members accountable to the guidelines and as an industry we need to support them in doing so. Absent this, there is a real risk of corrective regulatory or legislative action, which we all agree is not in the industry’s best interest. Let’s come together as industry partners to keep our own house in order to ensure Toll-Free technology can continue to keep us connected for years to come.

 

Gina Perini is the CEO of Somos, Inc., the neutral administrator of both the TSS Registry and the SMS/800 registry.