A first-party lender must use the phrase the reviewer looks for

The requirementstatement

A campaign whose business performs first-party lending must contain the literal phrase "Direct Lending" in its description.

Severityseverity: HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
When it bitesphase: Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
What is checkedobject: campaign.description
Where it liveslayer: CampaignCAMPAIGN
How Ekas settles itdetectability: AI · formAI_FORM; A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
What the fix involvesfailureClass: Fix the fieldRETRY_FIELD; A better value in the form fixes it. Ekas can rewrite it and re-check.
Who requires itauthorities: Twilio
When it appliesapplicabilityText: Applies when `directLending` is true.

Why this rule existsrationale

Lending campaigns are screened against a prohibited category that looks almost identical from the outside — the difference between a licensed lender servicing its own loans and a lead-generation operation is not visible in a sample message. The literal phrase is the marker the screening looks for, so a compliant lender that describes itself in its own words is sorted into the refused pile and given a rejection that reads as a content ban.

How to fix itremediation

Put the words "Direct Lending" in the description alongside your own account of the programme, and keep the directLending attribute true. Done when the phrase appears verbatim rather than as "we lend directly".

A compliant exampleexample

Harbor Point Lending is a Direct Lending business texting its own borrowers about payment due dates on loans it originated and services itself.

Common mistakespitfalls

The attribute and the phrase are separate requirements. Setting directLending true without the phrase leaves the screening with nothing to match on.

Provider rejection codescodes

The code you get back when this rule is what failed, and whether that provider lets you resubmit.

Provider	Code	Resubmit
Twilio	30895	Yes

Notesnotes

A Twilio phrasing requirement layered on top of the attribute itself. Not provider-tagged: including the phrase costs a compliant lender nothing anywhere else, and a tag would resolve YES on an unknown submission target regardless, so the tag would buy no protection while spending one of the three the registry allows itself.

Rules you will hit next

6 other rules read campaign.description. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.

CMP-035The description must describe this programme, not messaging in generalBlockingBLOCKING CMP-037The description must name the business that sends the messagesBlockingBLOCKING CMP-DESC-LENCampaign description must be 40–4096 charactersBlockingBLOCKING MSG-DESC-QUALITYCampaign description must explain who, what, and how they opted inBlockingBLOCKING CMP-041The description must say how often the messages comeHighHIGH CMP-042A programme that asks for money must say soHighHIGH

All campaign rules

CMP-051 is one of 94 campaign rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.