This article is for informational purposes only and is not intended as legal advice. If you need legal advice, please contact your preferred legal counsel.
Congratulations on your decision to implement ringless voicemail into your business! We understand the importance of protecting your organization's interests and the safety of your customers and we would like to provide you with some general information to help you comply with regulatory obligations and to help you prevent bad actors from using your account to commit fraud or other crimes.
As a service provider, you should have a "Know Your Customer" (KYC) process in place as directed by the FCC. This process involves obtaining identity verifications for your customers through a secure third-party vendor such as Vouched.id. It is your responsibility to know your customer and stop bad actors from using your services.
Additionally, allowing your customers access to send ringless voicemail requires that you gather evidence that your customers have pre-existing business relationships and/or are obtaining "prior express consent" from their contacts. Each of your customers will likely have a different procedure for obtaining opt-in and we find slides 9 through 11 of the following document to be a useful resource:
It's also important to remember that the content of your customer's pre-recorded audio used in campaigns must be in compliance with TSR Guidelines and/or any other regulations that apply to your customer's industry or message content. Generally speaking, this means that the caller's legal name (i.e. company name, DBA, or Sole Proprietor's legal first and last name) is clearly stated at the beginning of the recording, followed by a clear and concise reason for the call. An example of best practice would be something like, "Hi, this is Jane Doe from Example Company. I wanted to touch base with you about..."
Ensuring compliance with these regulations is important in protecting consumers from fraud and illegal activity. Please keep a record of your KYC and evidence of express prior consent so that you can assist regulators or law enforcement with their investigation efforts if it is ever needed.