1. Purpose

This Messaging Compliance Policy ("Compliance Policy") establishes the standards Telv Communications requires of clients who engage Telv for SMS registration, provider integration, and managed compliance operations. It sets out the regulatory framework governing commercial messaging, the client obligations Telv enforces as a condition of service, and Telv's role in the compliance process.

Telv's services are designed to help businesses build and maintain compliant SMS programs. Telv will not provide registration support, evidence preparation, or compliance advisory services for programs that do not meet the standards described in this Policy.

2. Applicable Regulatory Framework

Commercial SMS programs in the United States are subject to multiple overlapping regulatory frameworks. Clients must be familiar with and comply with all applicable requirements, including:

2.1 Telephone Consumer Protection Act (TCPA)

The TCPA (47 U.S.C. § 227) restricts the use of automated dialing systems and pre-recorded messages to mobile phones. For text message programs:

• Prior express written consent is required before sending marketing or promotional SMS to a consumer's mobile phone
• Consent must be clear, conspicuous, and not bundled with non-consent-related agreements
• Consent to receive texts is not a condition of purchasing a product or service
• Revocation of consent must be honored promptly

2.2 CAN-SPAM Act

For SMS programs with a commercial component, the CAN-SPAM Act (15 U.S.C. § 7701) may apply, including requirements for identification, prohibition on deceptive headers, and honoring opt-out requests.

2.3 CTIA Messaging Principles and Best Practices

The CTIA publishes industry guidelines adopted by carriers as conditions of use. Key requirements include:

• Clear opt-in with disclosure of message frequency, content type, and applicable charges
• Immediate opt-out processing upon receipt of STOP (or equivalent keywords)
• HELP response with program identification and contact information
• No facilitation of spam, spoofing, or content that violates carrier acceptable use policies

2.4 10DLC Registration Requirements

Businesses sending Application-to-Person (A2P) SMS via 10-digit long code numbers must register their brand and campaign with The Campaign Registry (TCR). Requirements include:

• Accurate business entity registration
• Declared use case consistent with actual message content
• Opt-in documentation and consent language that matches actual consumer-facing flows
• Compliance with carrier-specific campaign vetting requirements

2.5 Toll-Free Number Verification

Businesses sending commercial SMS via toll-free numbers are subject to carrier verification requirements, including submission of opt-in evidence, message samples, and traffic volume estimates.

2.6 Short Code Programs

Short code programs are subject to carrier review and program approval. Carrier Compliance requirements govern message content, frequency, opt-in/opt-out mechanics, and consumer disclosures.

2.7 State Laws

Several states have enacted their own consumer messaging or telephone privacy laws that may impose requirements beyond federal law. Clients are responsible for assessing and complying with state-specific requirements applicable to their operations.

3. Required Opt-In Standards

As a condition of receiving Telv's registration and compliance services, clients must ensure that their consumer opt-in mechanisms meet the following minimum standards:

3.1 Express Written Consent

The opt-in mechanism must:

• Clearly identify the business sending the messages
• Describe the program type (promotional, transactional, service alerts, etc.)
• State the approximate message frequency (e.g., "up to 4 messages per month")
• Include a statement that message and data rates may apply
• Include instructions for opting out (e.g., "Reply STOP to cancel")
• Include instructions for getting help (e.g., "Reply HELP for help or call [phone]")
• Include a link to or statement about the Privacy Policy
• State clearly that consent is not a condition of any purchase

3.2 Unchecked Default

Opt-in checkboxes must default to unchecked. Pre-checked consent boxes are not valid under TCPA and will not be supported by Telv.

3.3 Consent Not Bundled

Consent to receive SMS may not be buried in a general terms-of-service agreement. It must appear as a standalone disclosure or checkbox.

3.4 Accurate Opt-In Evidence

The opt-in screenshots, recordings, or flow descriptions submitted to Telv for registration purposes must accurately reflect the opt-in mechanism as it appears and functions for consumers at the time of submission, and must remain accurate throughout the program's operation.

4. Required Opt-Out Handling

Clients must honor opt-out requests from consumers. Minimum requirements:

• All programs must recognize STOP, STOPALL, UNSUBSCRIBE, CANCEL, QUIT, and END as opt-out keywords
• Opt-out requests must be processed within one business day
• A single confirmation message may be sent acknowledging the opt-out; no further messages may be sent to an opted-out number
• Opt-out records must be maintained and suppression lists must be applied to all future sends
• Consumers who later re-opt-in must do so through an active opt-in mechanism; prior opt-out records do not authorize future messages

5. Message Content Standards

All messages sent through programs supported by Telv must comply with the following content standards:

5.1 Identification

Messages must clearly identify the sending business or program. Consumers must be able to identify who is texting them without additional research.

5.2 Prohibited Content

Telv will not support registration or compliance work for programs that send, or intend to send:

• Unsolicited commercial messages to recipients who have not provided prior express consent
• Sexually explicit content
• Content promoting illegal goods or services
• Phishing, spoofing, or deceptive content
• Messages falsely representing the sender's identity
• Content that violates any carrier acceptable use policy

5.3 Consistency with Registration

The messages actually sent by a registered program must be consistent with the use case, content description, and sample messages submitted during the registration process. Material deviations from the registered use case may result in carrier suspension and require re-registration.

6. Telv's Role in Compliance

6.1 What Telv Does

Telv reviews, organizes, and prepares the documentation that messaging providers and registries require to evaluate a program for approval. This includes:

• Reviewing opt-in page screenshots and consent language against the standards in this Policy
• Organizing business identity and verification documentation
• Preparing registration evidence packages for submission
• Flagging potential issues for client remediation before submission
• Managing provider correspondence and follow-up

6.2 What Telv Does Not Do

Telv does not:

• Guarantee approval of any registration submission
• Provide legal advice or substitute for qualified legal counsel
• Assume responsibility for client compliance with TCPA, state law, or other applicable legal requirements
• Maintain or process individual end-user consent records on behalf of clients
• Send messages or operate as a messaging provider

6.3 Non-Compliant Programs

Telv reserves the right to decline to provide services, pause an active engagement, or terminate a service agreement if Telv reasonably determines that a client's program:

• Does not meet the standards set forth in this Policy
• Has been suspended or rejected by a carrier or registry for compliance reasons that the client declines to address
• Involves use cases that Telv determines carry unacceptable regulatory, legal, or reputational risk

Telv's determination to decline or pause services does not constitute a legal judgment regarding the client's compliance status.

7. Client Acknowledgment

By engaging Telv's services, clients acknowledge that:

1. They have read and understand the regulatory requirements described in this Policy
2. Their messaging program meets, or will be brought into compliance with, the opt-in standards in Section 3 before messages are sent
3. They are solely responsible for their program's ongoing compliance with applicable law
4. Telv's advisory review does not constitute a legal opinion or guarantee of compliance
5. They will promptly notify Telv of any carrier suspension, registry rejection, or regulatory inquiry related to their program

8. Updates

Carrier requirements, registry standards, and messaging regulations evolve frequently. Telv will update this Policy to reflect material changes in the regulatory and carrier landscape. Clients with active programs may be notified of changes that directly affect their program.

9. Contact

Questions about this Policy or the compliance standards applicable to your program should be directed to:

Telv Communications Compliance Inquiries Email: [email protected]