Textopoly Mobile Blog » MMA

Pre-Emptive Audits & Off-the-Cuff Requirements

Naushad — Mon, 09 Nov 2009 05:15:40 +0000

“Why does it take so long to get a short code approved?” It’s the million dollar question we’re asked day after day, and the truthful answer is “it depends.” It depend on the type of service being applied for, as well on the individual Carrier. There is no uniform system or guidelines in place from Carrier to Carrier which is quite unfortunate.

Delays in certification also arise when Carriers all of a sudden make up new requirements and last minute unreasonable requests.

Here are two recent occurrences that had us running in circles, throwing up our hands in utter disbelief and clinching our fists in a solemn swear that at least on a personal level we will never become users of this one particular Carrier. I won’t mention their name, but they are 1 of the top 4 in the U.S. For ease of reading we’ll just call them Queen Bee Mobile (QBM).

Pre-Emptive Audits: A team member came to me the other day to tell me about an audit we received from QBM . The audit was scolding us for not having a reply message when the auditor had text the keyword STOP to one of our managed short codes. This is a concern, and I asked the team member why he was talking to me about the audit and not resolving the audit! We are MMA members, strict on consumer compliance and this is a serious issue. The team member calmly said to me “The code isn’t provisioned, which means we have no technical connection to QBM which means that we’re incapable of receiving the STOP request and incapable of sending a text message to QBM users!” Yes, we were audited on a code that was still undergoing the strenuous process of certification! If you’re wondering how to solve pre-emptive audits give us a shout and we’ll fill you in. When I tell you the ends to which we had to travel to get this resolved you may want to stop doing mobile! (But don’t, it’s still a great space.)

Off-the-Cuff Requirements: Another recent client project required we apply for standard rate binary content, in this instance it was a wallpaper. After not hearing from QBM for 3 months, we receive an email with an Excel matrix of all QBM handsets, and a demand that we test the wallpaper download on each handset, tell QBM if it passed or failed, and provide the phone number to each of those handsets! Mind you, this requirement was not, and is still not documented. When we asked where this rule came from and the reasoning behind it we were told that the rule was to enhance user experience. What?! How exactly would this requirement meet that goal? In order to meet this goal all call to actions, including TV, Radio, Online, etc would need to list each and every handset that are compatible. This is obviously not realistic and fails on far too many levels for me to bore you with.

I mean, can you imagine the print, radio and television nightmare! And, where was this ‘rule’ 3 months ago when we applied for the code! Here’s the kicker, I told my Aggregator that my client that was going to do a wallpaper campaign is gone, because the process with QBM took too long. Thus, I didn’t want certification for binary download, just a standard rate SMS service which was also applied for at the same time. Simple right? Wrong! In order to do that QBM would need a brand new application just for the SMS alert service, they can’t (i.e. won’t) certify 1 service if the application asked for 2 – oh, and the cherry on top, I have to pay an additional application fee.

Alas, all of our frustration, agony and diatribes are a waste since Carriers control their backyards and we’re the ones that are asking permission to play in them. It’s the ultimate example of the “golden rule” – he who has the gold makes all the rules.

When these situations come up and we’re deflated the one thing we remind ourselves is that even though mobile can be frustrating when dealing with the Carrier/bureaucratic side of it, the client side is a fabulous eco-system the brings true value to consumers, quantifiable return on investment to brands, and pushes all of us to continue innovation. I truly hope Carriers realize this and focus more on supporting us rather than waking up on the wrong side of the bed and pulling random rules out of their . . .thin air

FCC Stepping In

Karla — Wed, 23 Sep 2009 16:45:34 +0000

The FCC announced its Wireless Innovation and Investment Notice of Inquiry (NOI) late August, catching mobile agencies in a spindle of perplexity and enthusiasm.

Stating that their intent is to merely gather facts about the wireless industry, the FCC will be focusing on research, innovation, and consumer protection (truth-in-billing). In other words, they will be looking at things such as mobile applications, policies, pricing information, consumer privacy, market competition, third party products and services and even what user phone bills look like. Conclusively the FCC wants to figure out their role in our evolving mobile ecosystem while also making sure that the mobile world is utilizing all current innovations and pushing for new state of the art technology.

Their interest in developing a framework for analyzing and measuring innovation in the mobile industry, however, seems farfetched, seeing as mobile is one of the most innovative classes of business. With a touch of a handset, anyone can go anywhere with his or her mobile GPS, surf the web with countless pages as options and update in real-time, receive alerts regarding weather, sports, health and much more. Consumer demands of mobile content and applications drive the mobile industry to new heights; and in return, the delivery of such content and applications satisfy consumer needs, creating a circle of daily deliverance of creativity and modern technology; which has successfully survived the economic downturn, all while regulating itself. So why would the FCC need to regulate mobile research and innovation?

Their interest in consumer protection and overall market competition, in my opinion, are the only valid claims they have in regards as to why they are stepping in, seeing as consumer privacy and protection is always, and should always be, a major focus amongst a plethora of markets. However, with Carriers, the MMA and the CTIA updating constantly in order to assure proper engagement of users, their privacy, and exposure to content, what more can the FCC do that the mobile world is not already trying to achieve and/or already regulating? In fact, the MMA is generating a response to the FCC and its inquiries; a response all marketing agencies should support.

Although we know that government-run operations have not had the best history, some mobile agencies are seeing this as an opportunity to raise issues that are usually down played when viewing mobile marketing as a whole, such as distress when it comes to Carriers and provisioning short codes. Moreover, as the FCC is enabling all mobile companies and agencies to submit their opinions, comments, and thoughts on any topic regarding their upcoming overview. Whether or not the mobile world likes what the FCC is going to do and might do in the future, this is a great opportunity for the mobile world to voice its concerns, backup our success with data, and successfully display whether or not the FCC needs to step in.

The Now Network is Now Specific

Karla — Tue, 15 Sep 2009 00:23:33 +0000

Sprint launched its new Compliancy Program in early July. Since then companies and agencies are scrambling through the Power Point and asking themselves if the Now Network is now too specific.

Sprint’s new attention to minor details and demands might be a bit too excessive for some. For example, the Mobile Marketing Association (MMA) regulation for an opt out message is phrased as “text STOP 2 stop”. For Sprint users, however, the Carrier requires different language! This causes a small programming hiccup in that brands will need to setup the message flow for Sprint differently and since Sprint’s required language is longer than the MMA, Sprint users will be delivered less content from the brand. The larger issue with some of these new policies by Sprint is that the inconsistency of rules make our industry appear defragmented, conclusively making entering the mobile marketing world increasingly difficult and off putting.

In fact, specifications from the Now Network sometimes override the Consumer Best Practices (CPB) guidelines, a globally followed regulatory document created by the MMA. For example, the CBP guidelines state that renewal dates need not be mentioned (page 19), in the text to the user, Sprint demands its display (page 87).

Failure to follow these Now Network rules may lead to violations in Sprint’s Severity Violation System. This is a system where violations are rated 1 to 3, with 1 being major and 3 being minor. Violations lead to other unflattering procedures such as audits, which recently, Sprint has been dishing out quite generously. Some repeated violations may lead to termination of the short code.

All this leads me to ponder, if the majority of brands are already abiding by CBP guidelines, which are drafted by Aggregators, major Content Providers AND Carriers, will brands choose not to support Sprint as a participating carrier from their campaigns? I don’t think this will be case, but if individual Carriers begin drafting rules that conflict with what the Best Practices Guidelines say, then what is the value of that document? More importantly, when will the U.S. mobile market have consistency of services, programs, rules and regulations so that developers and spirited innovators can further push this exciting industry?

Although the Now Network may intend to create a more happy mobile world with its compliancy program, they must admit that their policies somewhat differ from the CPB and can potentially lead to some confusion and misdirection.