Client Advisory | General Regulatory & Legal Advisory | Firm News and Events

The Opportunities and Risks of 10 Digit-Long Codes and Bulk Business Text Messaging

Earlier this year, Linda McReynolds, Of Counsel to Marashlian & Donahue, participated in a webinar hosted by the Cloud Communications Alliance (CCA). Ms. McReynolds spoke about the potential opportunities and risks of ten-digit long codes (10DLC), which allow companies to directly text their customers through local numbers. Ahead of the webinar, Ms. McReynolds also recorded a brief podcast discussing the issue.

During the webinar, Ms. McReynolds emphasized the emergence of 10DLC. Using this technology, businesses can send bulk text messages to customers using a local number. This may not seem like much, but this allows customers to recognize these numbers while engaging with companies and even call them back to speak with a representative. Today, most business-to-customer text messages come from SMS short codes, which are expensive for the business and do not allow customers to call businesses directly.

 While 10DLC offers a cost-effective and efficient way to communicate with consumers, it presents certain risks that should not be ignored. Notably, 10DLC may increase the amount of spam texts received by consumers, thereby eroding consumer trust similar to what has occurred with spam calls. The Federal Communications Commission (FCC) has made spam prevention a top priority, so one can assume that it would pursue spam text messages with similar fervor.

Additionally, Ms. McReynolds pointed out that, in order to take advantage of 10DLC, companies must register with The Campaign Registry – a private, industry-created entity that keeps track of what entities are sending business texts and the purposes of these messages. If a business fails to register, it may face various consequences imposed by the carrier, including blocked texts and fees.

Businesses interested in implementing text messages through 10DLC must determine how best to allocate these burdens and fees. Further, carriers must understand that registration fees and procedures are somewhat negotiable and should review their agreements with customers and vendors to understand their risks and responsibilities.

The CCA is a professional organization that focuses on advancing the cloud communications industry. It regularly provides virtual and in-person events to provide a forum to discuss important developments in all things cloud communications.

Ms. McReynolds’ practice focuses on data privacy and the telecommunications and technology sectors. She counsels clients on issues arising under the Telecommunications Act and federal and state laws addressing privacy and data security. As a practitioner, she recognizes clients’ needs to develop good practices and address compliance with applicable laws while achieving business success in the fast-paced technology and telecommunications sectors. Further, as a Certified Information Privacy Professional, Ms. McReynolds assists clients in developing and implementing of privacy and data security policies, information management programs, and managing risks associated with handling personal information without sacrificing a client’s business goals.

If your company would like to explore the possibilities and pitfalls presented by 10DLC and business-to-consumer text messaging, please contact Linda McReynolds at or (703) 714-1318. Further, feel free to review the recording of the podcast and webinar for more information.


Related Resources

Related Insights and Advisories

Sign up for our email list to receive notifications regarding new advisories and news:

Ask An Attorney

Ask An Attorney