{
  "id": "OPS-092",
  "slug": "ops-092",
  "title": "Local time is where the recipient is, not what their area code says",
  "statement": "The recipient's local time must be derived from their actual location, not from the area code of their number.",
  "rationale": "Numbers are portable and people move, so area codes stopped being geography years ago — a 212 number in Los Angeles is common, and a programme timing sends off it will message that person at 5am. This one assumption breaks every timing rule at once, and it is the default in almost every scheduler because the area code is the only location the phone number offers.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "recipient location resolution",
  "severity": "HIGH",
  "detectability": [
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC",
    "state law"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Time sends from a location you actually hold — the billing or shipping address, the account's stated location, the timezone the app reports — and fall back to a conservative window rather than to the area code where you hold none. Done when a customer with an out-of-state number is messaged on their own clock.",
  "example": "Schedule against profile.timezone where set; where unset, send only between 10am and 7pm Eastern, which is inside every US window.",
  "pitfalls": [
    "A conservative national window is a legitimate answer and often the right one — the narrow band that satisfies every state is a few hours, and most programmes do not need more."
  ],
  "notes": "Scheduler logic we cannot see. What the user has to decide is what location data they hold and are willing to rely on, because the alternative is not the area code — it is a narrower universal window.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "What location do you actually hold for each recipient — and is a customer with an out-of-state number messaged on their own clock?",
    "howToCheck": [
      "Decide which location data you hold and will rely on: the billing or shipping address, the account's stated location, the timezone the app reports.",
      "Where you hold none, fall back to a conservative national window rather than to the area code.",
      "The narrow band that satisfies every state is a few hours wide and most programmes do not need more."
    ],
    "failureLooksLike": "A 212 number in Los Angeles is common, and a scheduler timing off the area code messages that person at 5am. It is the default in almost every scheduler, because the area code is the only location a phone number offers."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-092/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-092.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}