Verbal Script Missing Fee Disclosure
Why This Rejection Happens
The verbal script provided for opt-in consent failed to include the mandatory fee disclosure statement. Even though SMS is often unlimited on modern plans, carriers legally require the sender to warn consumers that "Message and data rates may apply."
Common Triggers: Scripts asking "Can we text you?" without adding "Standard rates apply," or only mentioning message frequency (Code 2110) but forgetting fees.
Root Cause Analysis
Primary Triggers
- Assumed Knowledge: The sender assumed that "everyone knows texting is free" and omitted the disclosure. Compliance rules do not allow assumptions.
- Brevity: The script was shortened for conversational flow, cutting out the "legal" sounding parts.
- Incomplete Template: The script was copied from an old template that predates strict 10DLC enforcement.
Required Elements
| Element | Required Language | Rationale |
|---|---|---|
| Fee Disclosure | "Message and data rates may apply" | Warns user of potential costs (e.g., pay-per-text plans or data usage). |
| Timing | Spoken before or during consent | User must accept potential costs before agreeing. |
| Alternative | "Standard rates apply" | Acceptable shorthand, but "Msg & Data rates" is preferred. |
Step-by-Step Remediation
Locate the Verbal Script
Find the text you entered in the "Call-to-Action / Message Flow" description field of your campaign registration.
Insert the Mandatory Phrase
Add the sentence "Message and data rates may apply" clearly within the script.
✓ Compliant Script
"Do you want to receive appointment alerts from Dr. Smith? Message frequency varies. Message and data rates may apply."
✗ Non-Compliant Script
"Can we text you regarding your appointment?"
(Missing fee warning.)
Verify Other Disclosures
While fixing the fee disclosure, ensure you haven't deleted the Brand Name (Code 2108) or Frequency (Code 2110). They must all be present.
Carrier-Specific Requirements
T-Mobile
- Strict adherence to CTIA guidelines. Any missing fee disclosure in the primary opt-in script is grounds for rejection.
AT&T
- Checks for the phrase "rates may apply." Avoid creative paraphrasing like "it might cost money." Stick to the standard legal verbiage.
MyTCRPlus Tools That Can Help
Consent Form Builder
Generates scripts that automatically include the "Msg & Data rates may apply" clause.
Use This Tool →Audit Documentation Generator
Create standardized script cards for employees to ensure they read the fee disclosure every time.
Use This Tool →Pre-Resubmission Checklist
- The script contains "Message and data rates may apply" (or "Standard rates apply").
- The disclosure is part of the script text, not just an attachment.
- The Brand Name is also in the script.
- The Message Frequency is also in the script.
- I have updated the "Call-to-Action" description field in the portal.
Common Mistakes to Avoid
❌ "Texting is free"
Never tell a customer "texting is free" in the script, even if you don't charge them. Their carrier might. You must warn them that rates may apply.
❌ Paraphrasing
Don't say "Your carrier might charge you." Use the industry-standard phrase: "Message and data rates may apply." It is universally recognized by vetting agents.
Expected Timeline
This guidance provides general information about 10DLC compliance requirements. While message fees are rare on modern plans, the legal requirement to disclose potential carrier charges remains mandatory. Organizations should ensure their scripts include all required disclosures to prevent compliance violations. MyTCRPlus does not provide legal advisory services or regulatory representation.