{
  "id": "OPS-110",
  "slug": "ops-110",
  "title": "Some states require the seller to register before texting residents",
  "statement": "Before texting a state's residents, determine whether the seller must register with that state and post a bond.",
  "rationale": "Texas requires telephone solicitors to register with the Secretary of State, per location, with a bond — an obligation that has nothing to do with the carriers and that no part of the 10DLC process mentions. It is discovered through an enforcement letter rather than a rejection, and the registration cannot be applied retrospectively to the sends already made.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "state seller registration",
  "severity": "BLOCKING",
  "detectability": [
    "EXTERNAL_DATA"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "state law (TX)"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Check the seller-registration requirement for every state you solicit into before the first send, and register where it applies or exclude the state until you have. Done when the states you message are the states you are permitted to solicit in.",
  "notes": "A state filing, entirely outside the messaging stack. What the user has to do is take legal advice on which of their sends count as solicitations and which states they reach — carrier approval says nothing about either, and this is the clearest case in the framework where approval is not permission.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "For every state you solicit into, have you checked whether the seller must register and post a bond there?",
    "howToCheck": [
      "Take legal advice on which of your sends count as solicitations and which states they reach.",
      "Texas requires telephone solicitors to register with the Secretary of State, per location, with a bond.",
      "Register where it applies, or exclude the state until you have."
    ],
    "failureLooksLike": "No part of the 10DLC process mentions it, so it arrives as an enforcement letter rather than a rejection — and the registration cannot be applied retrospectively to sends already made."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-110/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-110.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}