A revocation crosses media

The requirementstatement

A revocation sent by text also stops robocalls to that number, and a revocation given on a call also stops texts.

Severityseverity: BlockingBLOCKINGBreaking this rule gets the submission rejected. There is no partial credit.
When it bitesphase: After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
What is checkedobject: suppression list scope across voice and SMS
Where it liveslayer: OperationalOPERATIONAL
How Ekas settles itdetectability: Post-submissionUNDETECTABLE_PRE_SUBMISSION; The subject does not exist yet at submission time: a reply window, an expiring PIN, a queue position. Reported with its deadline.
What the fix involvesfailureClass: Wait on someone elseTERMINAL_EXTERNAL; Needs an external system or a waiting period, such as IRS propagation, a vetting result, or a carrier queue.
Who requires itauthorities: FCC
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

The consumer revoked consent to be contacted by an automated system, and the FCC does not slice that by medium. Brands slice it anyway because the dialler and the messaging platform are different products with different suppression lists, so a customer who told the agent to stop calling then starts receiving texts — which reads as retaliation and is one of the most reliably complained-about patterns there is.

How to fix itremediation

Hold one suppression list across voice and messaging, or synchronise the two in both directions on the same day. Done when a STOP text removes the number from the dialler as well as from the campaign.

A compliant exampleexample

One do-not-contact table, consumed by both the dialler and the messaging platform, keyed on the number.

Check this yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

Does a STOP text remove the number from the dialler as well as from the campaign — and does a revocation given on a call stop the texts?

1Check whether one suppression list covers voice and messaging, or whether two are synchronised in both directions on the same day.
2Most brands that have a sync built it to feed the dialler and not to be fed by it. Check the direction.

What wrong looks like: A customer tells the agent to stop calling and then starts receiving texts. It reads as retaliation and is one of the most reliably complained-about patterns there is.

Notesnotes

Two systems, neither visible from a registration. What the user has to check is the direction of any existing sync — most brands that have one built it to feed the dialler and not to be fed by it.

Rules you will hit next

Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.

OPS-026The universal opt-out keyword set must be declaredBlockingBLOCKING OPS-027Opt-out keyword handling must be declared, not assumedBlockingBLOCKING OPS-029A revocation must survive punctuation, case and surrounding wordsBlockingBLOCKING OPS-031A plainly-worded opt-out counts even with no keyword in itBlockingBLOCKING OPS-033STOP must never come back as an errorBlockingBLOCKING OPS-037On a shared address, STOP must stop everythingBlockingBLOCKING

All operational rules

OPS-043 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.