{
  "id": "OPS-215",
  "slug": "ops-215",
  "title": "Express written consent must name the specific number and bear a signature",
  "statement": "The retained consent agreement must identify the specific telephone number consented for and bear the consumer's signature.",
  "rationale": "TCPA express written consent is a signed agreement naming the number, and an electronic signature under E-SIGN qualifies — a ticked box with a stored identity and timestamp satisfies it. What does not satisfy it is a record that cannot tie a signature to a specific number.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "campaign.message_flow",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "FCC"
  ],
  "applicability": {
    "useCases": [
      "MARKETING",
      "MIXED",
      "SWEEPSTAKE",
      "LOW_VOLUME"
    ]
  },
  "applicabilityText": "Applies when the use case is MARKETING, MIXED, SWEEPSTAKE and LOW_VOLUME.",
  "universal": false,
  "remediation": "Ensure the consent record ties an identifiable signature — including an E-SIGN electronic one — to the specific number, and describe that linkage in the message flow.",
  "example": "The checkbox action, the entered phone number, the consenting account identity and the timestamp are stored together as the signed agreement.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/operational/ops-215/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-215.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}
