FREQUENTLY ASKED QUESTIONS, UNITED STATES

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1 FREQUENTLY ASKED QUESTIONS, UNITED STATES Accessing the CTIA In-Market Monitoring Portal 1. Q. How do I register to receive CTIA audits as a content provider? Content provider contacts are assigned per shortcode and are validated against the content provider and compliance contact fields in the CSC Registry. After verifying that both of these fields point correctly to the content provider in control of the shortcode, contact the CTIA Compliance Team at the Support Desk at support.ctia@psmsindustrymonitor.com with your compliance contact update request. Updates are not retroactive. Content provider and compliance contact updates go into effect for all new audits issued after the update. 2. Q. How do I register to receive CTIA audits as an application provider or associated party? Currently, only content providers, aggregators, carriers, and the CTIA can access audit data in the CTIA In-Market Monitoring Portal (IMM Portal). 3. Q. How do I register to receive CTIA audits as an aggregator? Aggregators obtain access to the IMM Portal in one of two ways. The company listed in the aggregator field for a shortcode in the CSC Registry can access audit data for that shortcode. Aggregators associated with a shortcode on any of the participating carrier networks (i.e., AT&T, T-Mobile, Sprint, US Cellular, or Verizon Wireless) also have permission to view audit data for that shortcode. If your company is not associated with a shortcode in the IMM Portal and you believe it should be, please ensure that the proper updates have been made in the CSC Registry and participating carrier networks. Sometimes a delay occurs between updates entered and updated information being provided to the CTIA Compliance Team. If such is the case, contact the Support Desk at support.ctia@ psmsindustrymonitor.com. Only aggregators with direct connections to participating carriers can receive aggregator-level access to the IMM Portal. 4. Q. How do I register to receive CTIA audits as a carrier? If you are associated with a participating wireless carrier AT&T, T-Mobile, Sprint, US Cellular, or Verizon Wireless please contact support.ctia@psmsindustrymonitor.com for help logging into the IMM Portal. If your company is not currently associated with the CTIA Compliance Monitoring program and is interested in joining, please contact the CTIA directly. 5. Q. I received a Program Violation Notice. How do I request login credentials to see my audit in the IMM Portal? If you received a CTIA Program Violation Notice directly from compliance@psmsindustrymonitor.com, either your address or an distribution list to which you subscribe was submitted to the CTIA Compliance Team as the compliance contact for a shortcode in the IMM Portal. If you have no account or have forgotten the username for your account, please contact support.ctia@ psmsindustrymonitor.com with the specific shortcode and audit number you are attempting to access. If an audit was forwarded to you by a third party or if you are requesting login credentials proactively, you must register to receive CTIA audits (see FAQs 1 4). Be ready to provide a specific shortcode or audit number with which you need help. 6. Q. I have my username and password. How do I log into the IMM Portal? Log into the IMM Portal at Enter your username and password and complete the CAPTCHA to gain access. 7. Q. How do I reset my password? If you have forgotten your password to the IMM Portal, you can reset it at by entering your username and address. The address you entered must be associated with the account in the IMM Portal. The new password is randomly generated and is delivered to all addresses associated with the account. WMC Global FAQs Page 1

2 8. Q. How do I reset my username? Usernames cannot be reset. One username is created for each account in the IMM Portal and must be shared among all users of that account. If you have misplaced your username, please contact support.ctia@psmsindustrymonitor.com from an address associated with the account in question. 9. Q. Can I set my password on my own so remembering it is easier? No. All passwords are randomly generated. 10. Q. I am logged into the IMM Portal. Why am I unable to see the audit I am trying to access? Verify that the account you are logged in under has permission to access the audit you are trying to view. To have permission to view an audit your account must be listed as the content provider or aggregator for the shortcode in question. Reading Program Violation Notices 11. Q. What is a Program Violation Notice? A Program Violation Notice is a document distributed via to the content provider, aggregator or aggregators, and carriers associated with a shortcode, notifying these parties that a violation or violations have been found in related advertising. Likewise, a Message Flow Violation Notice contains an audit (with specific violations cited) of the service messages associated with a specific shortcode. 12. Q. On what day do aggregators and content providers receive the weekly Program Violation Notices? The PSMS Industry Monitor ticketing system issues Program Violation Notices every Monday. 13. Q. What do the severity levels associated with violations in the Program Violation Notices mean? The severity levels indicate the seriousness of the Program Violation Notice and the amount of time, from the notice date, that the carrier allows the content provider to correct the violations cited. The CTIA allows two business days for severity 1 Program Violation Notices to be corrected and five business days for severity 2 Program Violation Notices to be corrected. Severity 0 Program Violation Notices must be corrected immediately. 14. Q. How do I view an audit referenced in the Program Violation Notice? The Program Violation Notice contains a link to a PDF version of the notice. Click on this link, and follow the instructions on the login page. 15. Q. Why is the Program Violation Notice divided into different groups? A single shortcode can appear in multiple noncompliant advertisements within a single week. Advertisements on the same shortcode that fail at the same severity level in a given week appear as different groups on the same Program Violation Notice. 16. Q. How do I know which exact URLs must be corrected? Click on the group thumbnail or thumbnails on the Program Violation Notice to see the details of each individual intercept. Some Program Violation Notices contain multiple groups and some groups contain multiple URLs. All violations on all URLs in all groups must be corrected by the cure date. 17. Q. How long ago was this audit performed? Program Violation Notices are published the Monday following the week that audits were conducted. As a result, data contained in Program Violation Notices is no more than five business days old. Click on the group thumbnail on the Program Violation Notice to navigate to the intercept details screen. The exact intercept date is listed on this screen. 18. Q. I was cited for a measurement-based violation, such as Pricing point size too small or T&Cs below the fold, but it looks compliant on my computer screen. Does evidence exist to support these citations? WMC Global FAQs Page 2

3 Yes. Click on the group on the Program Violation Notice to navigate to the intercept details screen. A link titled Additional Images on the intercept details screen will bring up a screenshot with the audit measurements displayed. Communicating with the CTIA Compliance Team 19. Q. Do both content providers and aggregators receive Program Violation Notices? Where WMC Global detects breaches of the audit standards, both the content provider and the relevant aggregator or aggregators receive a compliance notification via containing a URL link or links to their Program Violation Notices. 20. Q. Are separate Program Violation Notices issued to the same content provider and aggregator for the same violations across each carrier network? The CTIA Compliance Monitoring program distributes only one audit with a single set of violations on behalf of all participating carriers. However, individual carriers are free to maintain their own compliance monitoring programs, and audits associated with these programs are delivered separately and must be addressed separately. 21. Q. Why did I receive a Program Violation Notice from the PSMS Industry Monitor? If you received a CTIA Program Violation Notice directly from the address compliance@psmsindustrymonitor.com (i.e., the audit was not forwarded to you), your contact information was provided to the CTIA Compliance Team as the compliance contact for the audited shortcode. If you believe that you have received this notification in error, contact the Compliance Team at support.ctia@ psmsindustrymonitor.com. 22. Q. Who is supposed to respond to audits? Is it the content provider s responsibility or the aggregator s? The content provider holds primary responsible for resolving audits, but the carriers participating in the CTIA Compliance Monitoring program likely will contact aggregators for details regarding unresolved audits. 23. Q. What will happen if I ignore an audit? The CTIA can suspend shortcode lease renewals for outstanding compliance violations, and additional action can be taken at the carrier level. 24. Q. How do I respond to an audit to issue a dispute, request a retest, or communicate with the compliance team? Aggregators and content providers simply reply to the they receive from the PSMS Industry Monitor ticketing system, maintaining the subject line of the original audit notification . sent to this address without the correct subject line is routed incorrectly. Aggregators also can access the IMM Portal to respond to a Program Violation Notice directly. 25. Q. Should content providers disagree with an audit, what recourse do they have? Content providers who feel they have a legitimate claim may appeal an audit by responding appropriately to compliance@ psmsindustrymonitor.com within 48 hours of receiving a compliance notification. The message should state explicitly why the content provider deems the audit incorrect and should include proof to validate this claim. The CTIA Compliance Team assumes primary responsibility for handling such challenges as it does for compliance monitoring and routine enforcement. The Team will review the audit challenge to determine whether mitigating circumstances might apply. Should the Team find that the challenge is invalid, it will notify the content provider that the audit is upheld and that the violation or violations must be corrected without further delay. If, however, the Team believes the content provider has presented a valid case, it will forward to the CTIA and participating carriers the appeal details for further discussion. The outcome of the appeals process will be validated on a per-creative basis at carrier discretion. 26. Q. Why am I receiving duplicate Program Violation Notices citing the same advertisement or advertisements on the same shortcode in successive months? The CTIA Compliance Monitoring program reviews programs monthly to ensure ongoing compliance, regardless of the status of previous audits. Extended delinquency will not prevent you from receiving new audits for the same issue in subsequent months. 27. Q. Why am I receiving duplicate Program Violation Notices from the CTIA citing the same advertisement or advertisements on the same shortcode in successive weeks? Why would these duplicate audits sometimes cite different violations? WMC Global FAQs Page 3

4 Each unique URL is regarded as a unique interception and, as such, is subject to audit and enforcement. So, although it might appear that your audits are duplicates, they actually apply to similar or identical creative intercepted on multiple different URLs. Moreover, advertisements that at first glance appear to be identical often have subtle differences. A close reading of the violations cited on the Program Violation Notices and the actions required to correct them will help you locate those differences among similar creative and understand the audits. Additionally, some individual carriers maintain compliance monitoring programs independently of the CTIA program. Overlapping of audits issued by individual carriers with audits issued by the CTIA is possible. 28. Q. What if the advertisement was corrected or removed before I received the Program Violation Notice? Audits are valid from the interception date, which is the date the screenshot is captured and time-stamped. This date should be no more than five business days before audit receipt. The audit is still valid if the issue is corrected before notification; however, if the violations are truly resolved, the audit can be closed right away. 29. Q. Sometimes complex issues can be resolved more efficiently and rapidly by phone than by . Does the CTIA Compliance Team have a Helpline that I may call for assistance in such cases? You may speak to a member of the CTIA Compliance Team at the Support Desk by calling (855) during normal business hours, 9:00 A.M. to 5:00 P.M. EDST, Monday through Friday. CTIA Audit Standards, Policies, and Procedures 30. Q. Why do the CTIA audit standards differ from the Consumers Best Practices guidelines published by the Mobile Marketing Association? The CTIA audit standards combine the Mobile Marketing Association (MMA) Consumers Best Practices (CBP) guidelines with individual carrier requirements. For the most part, rules contained in the CTIA audit standards can be traced back to the CBP. The format is different because while the CBP is composed of broad rules, the CTIA audit standards contain specific tests that evaluate compliance with the rules. 31. Q. Who wrote these audit standards? The CTIA and participating carriers developed the rules contained in the CTIA audit standards. 32. Q. Why must severity 1 violations be corrected within 48 hours? Isn t that an unreasonable timeframe? The violations enforced by the CTIA reflect rules outlined in the MMA CBP and were forged with carrier consensus. Therefore, all stakeholders should be thoroughly familiar with these requirements. Violations categorized as severity 1 are serious problems that impact consumer confidence and must be dealt with urgently. Content providers are expected to use the 30 day grace period before active enforcement begins to bring their advertisements and service messages into compliance. This grace period was designed to provide a comfortable timeframe to adjust advertising creative and service messages and thereby minimize the number of severity 1 Program Violation Notices that must be issued. 33. Q. What happens when a content provider is unable to resolve an audit by the cure date because it appears in a magazine ad or TV commercial that is still in the market? Media such as print and TV have a longer run cycle and, therefore, advertising in these media cannot be remedied as quickly and easily as online advertising. In such cases, the content provider should advise the CTIA Compliance Team of a reasonable estimated fix date and submit, within 30 days of receiving the Program Violation Notice, a JPG file or video clip of the corrected advertisement. On receiving an in-market fix date as well as a corrected JPG or video clip that brings the ad into compliance, the Team will update the status to Pending Retest. The Team subsequently will retest on the fix date to confirm the ad in market matches the approved creative. Ads intercepted in market on or past the fix date that fail to match the approved creative and, hence, fail to pass the retest will be escalated immediately to the CTIA and, subsequently, to the carriers. 34. Q. What can a content provider do to resolve an audit of an advertisement on a Website with which the content provider is unaffiliated? Although content providers need not own or manage the Webpages representing their offers, they nevertheless assume responsibility for ensuring that their offers are marketed in a manner consistent with CTIA audit standards. In cases where you are unable to control a Website and the cell-submit field or keyword promoted on that Website is nonfunctional you may submit to the CTIA Compliance Team a completed Audit Close Request Form. By completing and submitting this form, you agree that all keywords associated with this audit have been disabled and that they generate no revenue or traffic. If this Website remains uncorrected, you might receive another audit, in which case you must respond by contacting the CTIA Compliance Team via the Support Helpline or the ticketing system so an enforcement specialist can reconfirm that the keywords are still inactive. If these calls-to-action are found to be WMC Global FAQs Page 4

5 active, however, the new audit will be escalated to the CTIA for immediate action. 35. Q. Do we have to comply with audit standards enforced by individual carriers in addition to these CTIA audits? Yes. The CTIA Compliance Monitoring program in no way supersedes compliance programs implemented at the carrier level. 36. Q. How do I avoid receiving audits for programs that have carrier preapproval? The CTIA Compliance Monitoring program is cross-carrier, so unless all participating carriers agree to an exception to the rules, no exceptions are granted. 37. Q. Although my Website is unaffiliated with mobile, I received an audit. The offer just has a simple standard rate text alert feature to provide more information to users. Must I really put all of these terms and conditions on my Website? Yes. 38. Q. Are the requirements for terms and conditions in TV, print, and WAP advertising the same as the requirements for online advertising? At this time, yes, all PSMS calls-to-action must follow the rules in Appendix 1 of the CTIA Monitoring Compliance Handbook. Message Flow 39. Q. Is fitting all required terms and program details into a single SMS message possible without exceeding the character limit? Yes, including all required disclosures in each SMS message is possible. However, you might have to remove promotional or nonrequired text to do so. 40. Q. Do content providers respond in the same way to a Program Violation Notice for a message flow audit as they do for an advertising audit? Responding to a Message Flow Violation Notice is similar to responding to a Program Violation Notice for a print or TV advertisement. In preparation for retesting message flows, content providers must reply to the Message Flow Violation Notice with a complete message copy of their corrected flow. An enforcement specialist reviews the copy for corrections. Only message flows that have been determined to be compliant in the copy are actually retested live in preparation for closing the audit, as appropriate. When the flow copy submitted is still noncompliant, the enforcement specialist advises the content provider via the ticketing system that violations remain. Please note that no message flow is retested live unless the CTIA Compliance Team receives a complete message flow log that it can first verify is compliant. Audit Parameters 41. Q. I received an audit from the CTIA, but the audited creative does not display my shortcode. Why is this audit considered valid? When an advertisement displays no shortcode, a handset test is conducted and an audit is issued to the messaging shortcode. If a program delivers messages from a different shortcode than advertised, an audit is issued for the messaging shortcode based on a handset test. 42. Q. I received an audit from the CTIA, but the audited creative is nonfunctional. Why is this audit considered valid? Advertisements featuring carrier brands or logos are audited for compliance. Please remove all carrier branding from inactive pages. 43. Q. What is the MDN associated with this handset test or message flow? The CTIA Compliance Team cannot disclose specific MDNs used for testing. WMC Global FAQs Page 5