This is not legal advice. This is operational guidance based on the FCC TCPA rules, current A2P 10DLC carrier requirements, and how the snapshot handles each.
If your practice is doing serious SMS, work with a US-licensed attorney to confirm your compliance posture. The information here is current as of writing.
What TCPA covers
The Telephone Consumer Protection Act governs automated and AI-assisted SMS to US recipients. Key rules:
- Express written consent required for marketing SMS — not opt-out, not implied
- Narrower exemption for transactional messages (appointment reminders, payment confirmations) — still requires prior consent in most cases
- Time-of-day restrictions — no marketing SMS before 8am or after 9pm in the recipient’s local time
- Identification — every marketing SMS must identify the sender
- Opt-out path — STOP keyword must work; opt-out must be honored within 30 days (in practice, immediately)
Violations are litigated under TCPA’s private right of action with statutory damages of $500–$1,500 per violation. Class actions have settled in the $millions for coaching companies that ignored this.
What A2P 10DLC adds
Separately from TCPA, the major US carriers (T-Mobile, AT&T, Verizon) require Application-to-Person 10-Digit Long Code registration for any business sending automated SMS from a regular phone number.
Without 10DLC:
- Messages get rate-limited (most don’t deliver)
- Some carriers block entirely
- Spam scoring tanks your sender reputation
Registration requires:
- Brand registration (your legal entity, EIN, business address)
- Campaign registration (the type of SMS you’ll send + sample messages)
- Carrier approval (takes 1–4 weeks)
The snapshot files all this for US-based practices at no charge. Other providers charge $150–$300 for this work.
Setting up opt-in capture properly
Wrong:
[x] I agree to terms and conditions(Pre-checked, vague.)
Wrong:
By submitting this form you agree to receive marketing texts from us.(Implied consent. Not adequate under TCPA.)
Right:
[ ] I consent to receive automated marketing text messages from [Your Practice]
at the phone number above. Message frequency varies. Message and data rates
may apply. Reply STOP to opt out. View our Privacy Policy and Terms.(Unchecked, explicit, identifies sender, mentions cost, explains opt-out.)
The snapshot ships with this consent block pre-built on every form.
Implementing STOP / HELP / START
Carrier-required keywords:
- STOP (or STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT) — suppresses all future SMS from your account to that number
- HELP (or INFO) — returns your support contact info
- START (or SUBSCRIBE, YES) — re-opens after a previous STOP, requires renewed consent
The snapshot handles all of these automatically. STOP suppresses across all campaigns; HELP returns the configured support message; START requires the contact to go through opt-in again (not just text START — they have to fill the form again).
Documenting consent + archives
For each opted-in contact, the snapshot stores:
- Timestamp of opt-in
- Source URL (which form, which page)
- IP address + user agent
- Full message history (sent + received)
- Opt-out events with timestamp
Retention default: 7 years (matches FCC requirement). Configurable.
In the event of a TCPA complaint or class-action discovery request, this archive is your defense.
What this means for your coaching practice
If you’re running SMS-based accountability check-ins, reminders, or marketing:
- You need explicit consent from every recipient (the snapshot captures this)
- You need 10DLC registration if you’re sending from a US number (the snapshot files this)
- You need STOP / HELP / START handling (the snapshot does this)
- You need timestamped consent records (the snapshot stores this)
- You need to honor opt-outs immediately (the snapshot does this)
- You need to avoid the 8pm–9am window for marketing (the snapshot enforces this)
The compliance work is done. You just need to use it correctly.
What still requires your judgment
The snapshot can’t make you compliant if you:
- Manually message someone who never opted in
- Continue messaging someone after they’ve opted out (via SMS or via other channel)
- Send marketing under the cover of transactional messaging
- Ignore the time-of-day restriction in custom workflows
These are operational discipline, not platform capability.