Verbal consent records must substitute a call identifier for the IP address
The requirementstatement
Where consent was verbal or via IVR, a call identifier must replace the IP-address field in the consent record.
- Severityseverity
- MediumMEDIUMUsually survives review, but lowers your trust score or invites a manual look you would rather avoid.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- campaign.message_flow
- Where it liveslayer
- OperationalOPERATIONAL
- 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
- CTIAFCC
- When it appliesapplicabilityText
- Applies when consent was collected by live verbal and IVR.
Why this rule existsrationale
The IP field is meaningless for phone consent, and leaving it empty produces a record that looks incomplete rather than method-appropriate. A call ID, recording ID, or agent identifier is the equivalent evidence and is what a reviewer expects for that method.
How to fix itremediation
Store a call ID, recording ID, or agent extension on verbal consent records in place of the IP address, and say so in the message flow.
A compliant exampleexample
Verbal opt-ins store the call UCID, the agent ID, and the script version read, in place of an IP address.
Rules you will hit next
6 other rules read campaign.message_flow. 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-003Message flow must not begin or end with whitespaceBlockingBLOCKINGCMP-059Message flow must describe the mechanism end to endBlockingBLOCKINGCMP-060Every opt-in method in use must be listed in the message flowBlockingBLOCKINGCMP-061Each declared method needs its own complete workflow paragraphBlockingBLOCKINGCMP-072Message flow must state the message typesBlockingBLOCKINGCMP-073Message flow must state message frequencyBlockingBLOCKING
OPS-204 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.