Insurance Messaging Compliance

Complete Guide to 10DLC & TCR for Insurance Providers, Agencies, and Claims Management

5-Page Guide TCR Compliant Audit-Ready
1

Insurance SMS: Regulatory Complexity & Operational Pressures

Insurance messaging faces heightened regulatory complexity: state insurance department oversight, TCPA litigation prevalence, financial services restrictions, and consumer protection regulations exceed most other verticals. TCR rejection rates average 28-35% due to regulatory language concerns and predatory lending claim restrictions in compliance messaging.

Insurance Messaging Patterns

Insurance SMS usage spans multiple regulatory categories requiring separate TCR registrations:

  • Policy Updates Renewal notifications, policy change confirmations (Account Notifications)
  • Claims Status updates, document requests, claim decisions (Customer Care)
  • Billing Invoice delivery, payment reminders, cancellation notices (Account Notifications)
  • Agents Lead notifications, appointment confirmations, performance alerts (Account Notifications)
  • Underwriting Application status, quote expirations, additional information requests (Account Notifications)
  • Marketing Rate quotes, policy comparisons, promotional offers (Marketing - high friction)

Critical Regulatory Layer: GLBA Privacy Requirements

Insurance is regulated under the Gramm-Leach-Bliley Act (GLBA), which requires safeguarding of personally identifiable financial information. SMS containing policy details, coverage information, or sensitive customer data must include appropriate security disclosures. Carriers scrutinize insurance SMS for GLBA compliance and information security language.

Market Context

Insurance represents 10-14% of U.S. 10DLC volume, with auto insurance, homeowners, and health insurance being highest-volume users. The sector experiences 30%+ TCPA litigation rate (vs. 12% average), creating elevated compliance pressure and carrier scrutiny.

2

TCR Registration for Insurance Providers

Insurance TCR registration requires emphasizing customer service focus while addressing carrier concerns about financial services restrictions and information security.

Recommended Campaign Structure

Campaign Name Use Case Function Approval Rate
Policy Updates Account Notifications Renewals, changes 94%+
Claims Management Customer Care Status, documents 92%+
Billing & Payments Account Notifications Invoices, reminders 95%+
Insurance Marketing Marketing Quotes, promotions 65-75%

Brand Registration Best Practices

  • Business Description: Lead with service focus: "[Insurance Company] policy updates and claims coordination" vs. "insurance marketing platform"
  • Data Security Emphasis: Include: "GLBA-compliant customer communication with information security protocols"
  • Regulatory Documentation: Provide insurance license number, state insurance department registration
  • DUNS Registration: Obtain DUNS verification before TCR (+25 trust score points for financial services)

Avoid These Insurance Registration Errors

Common insurance TCR rejections stem from: sample messages containing policy amounts or detailed coverage information (GLBA concerns), marketing-focused descriptions ("lead generation," "customer acquisition"), unsubstantiated savings claims ("save up to 40%"), or predatory lending language (for payday loans, personal loans). Use service-focused descriptions emphasizing information security.

3

TCPA & GLBA Compliance Frameworks

Insurance SMS must satisfy dual compliance requirements: TCPA consent obligations plus GLBA information security and privacy requirements.

TCPA Consent Framework for Insurance

  • Policy Admin Transaction-related notifications permitted with limited consent (policy documents, renewal notices, payment confirmations).
  • Claims Processing Customer Care classification; limited consent required during claims submission.
  • Billing Reminders Account notification; required disclosure at policy inception.
  • Marketing SMS Promotional communications require explicit opt-in (rate quotes, policy comparisons, exclusive offers).

Insurance TCPA & GLBA Compliance Checklist

  • SMS opt-in disclosed in policy documents
  • Separate marketing SMS opt-in checkbox
  • SMS messages comply with GLBA confidentiality
  • Consent records retained with timestamps
  • STOP keyword responses sent within 48 hours
  • Info security disclosure in privacy policy

GLBA Information Security Requirements

Insurance SMS must implement GLBA-compliant information handling:

  • Sensitive Information Minimization: SMS contains only reference identifiers (policy number, claim number); detailed information via secure portal links
  • Secure Links: Use short URLs requiring authentication to access policy details or claims information
  • Encryption Protocols: Backend SMS platform must support encryption and secure transmission
  • Data Retention Limits: Log retention aligned with GLBA requirements (minimum 6 years)
  • Third-Party Restrictions: Ensure SMS vendor agreement prevents data access to unauthorized parties

Compliant Insurance SMS Examples

  • ✓ "Your policy #ABC123 renews 3/15. Review/renew: [secure-link]. Questions? Call [number]. -[Insurance Co]"
  • ✓ "Claim #XYZ789 received. We'll contact you within 48 hours. Track: [portal-link]. -[Insurance Co]"
  • ✓ "Your payment of $125 posted to policy #ABC123. Next due: 4/15. -[Insurance Co]"
4

CTIA Content Compliance & Regulatory Boundaries

Insurance SMS must comply with CTIA content guidelines plus financial services restrictions prohibiting predatory lending language and unsubstantiated claims.

Prohibited Insurance Content

  • Predatory Lending Language: "Get money fast," "Bad credit OK," "No documentation needed" (applicable to insurance financing/credit products)
  • Unsubstantiated Savings: "Save 40%" without disclaimer; no comparison basis stated
  • Discriminatory Targeting: Selective coverage offers based on protected classes
  • False Coverage Claims: Coverage guarantees without appropriate disclaimers and conditions
  • Health/Medical Claims: Unsubstantiated health benefits for health insurance products

State Insurance Department Requirements

Insurance SMS often requires state insurance department compliance beyond carrier standards:

  • Advertising Disclaimers: Many states require "INSURANCE ADVERTISEMENT" header on promotional SMS
  • Agent Identification: Agent-initiated messages must identify agent and agency
  • Rate Disclosure: Quote messaging must include clear rate conditions and exclusions
  • Complaint Procedures: Policy documents must include state-mandated complaint procedures accessible via SMS link

Messaging Frequency & Cancellation Notices

Insurance SMS requires careful cancellation notice handling. Policy cancellation messages must include state-mandated cancellation reasons and insured rights. Frequency limits apply to marketing; policy administration SMS permitted as necessary for account management.

5

Implementation & Operational Compliance

Insurance SMS implementation requires integration with policy management systems and compliance oversight ensuring consistent adherence across distributed operations.

Technical Implementation Requirements

  • Policy System Integration: Direct API connection to policy management system enabling automated renewal and billing notifications
  • Consent Database: Separate SMS preferences repository with opt-in status and communication preferences per policy
  • Message Templates: Pre-approved templates preventing unauthorized policy information disclosure
  • Secure Portals: All sensitive information accessed through authenticated portals, not transmitted via SMS
  • Audit Trail: Complete logging of all SMS with policy reference, timestamp, content, and user identifier

Compliance Monitoring

  • Quarterly Message Audits: Sample review of sent SMS for TCPA, GLBA, and state insurance department compliance
  • Customer Complaint Tracking: Monitor SMS-related complaints and investigation for TCPA violations
  • Carrier Feedback: Track carrier notifications for message blocks or policy violations
  • Regulatory Monitoring: Monitor state insurance department guidance for SMS-specific requirements

Pre-Launch Insurance SMS Verification

  • All TCR campaigns registered and approval status confirmed
  • SMS consent captured during policy enrollment and separately for marketing
  • Message templates reviewed for TCPA, GLBA, and state insurance requirements
  • Policy system integration tested for automated renewal and billing SMS
  • Secure portal authentication verified for sensitive policy information
  • Privacy policy updated with SMS disclosure and GLBA information security language

Multi-Channel Compliance Coordination

Insurance companies should coordinate SMS compliance with email and mail communications ensuring consistent messaging. Policy document disclosures must align with SMS opt-in language, and customer preference management should honor opt-out choices across all channels.

Industry Compliance Playbooks Bundle

Part of MyTCRPlus Professional Services Program

This playbook provides general compliance guidance based on TCR, TCPA, GLBA, CTIA, and state insurance department frameworks. Insurance providers should consult qualified legal counsel specializing in insurance regulation, TCPA, and telecommunications law. State insurance requirements vary; verify compliance with your state insurance department before SMS deployment.

© 2025 MyTCRPlus. All rights reserved. | Last Updated: February 2025