To comply with the Telephone Consumer Protection Act (TCPA), SALT has updated its consent process:
Consent Statements
Prospect-facing:
• SALT Forms: A consent statement is now included at the beginning of every SALT Form, ensuring prospects acknowledge and agree to communication policies upfront.
• Branding Settings: In your Branding Settings, you can add a custom Terms of Service (TOS) URL. This link will appear in the disclaimer to align with your agency’s policies.
SALT Agents & Employees:
• Phone Number Updates: A consent statement is also required whenever a customer enters or updates their phone number in their SALT profile.
Clearing Up Misconceptions: Why SALT Forms Are Not Subject to TCR Marketing Rules
Some texting and phone service providers have raised concerns about whether our white-labeled intake forms comply with The Campaign Registry (TCR) requirements. This often stems from a misunderstanding of the purpose and function of our forms, leading to incorrect assumptions that they fall under marketing and promotional messaging regulations.
In reality, our forms are used for insurance application intake, not SMS marketing or unsolicited outreach. However, because TCR primarily governs bulk messaging and promotional content, some providers mistakenly apply its requirements to our transactional communication process.
To help clarify this issue, we’ve outlined key points below that you can share with your phone provider as a reference for our established stance.
These updates reinforce that our compliance policy applies to both SALT customers and affiliated companies, ensuring coverage for your agency and its prospects.
[Key Points of Clarification]
Our Forms Are Not for Marketing Purposes
Our forms are designed for insurance application intake, not for SMS marketing, customer notifications, or promotional campaigns. When a consumer applies for insurance, they inherently expect communication from the agent handling their policy. Unlike marketing campaigns, this is transactional communication, not a solicitation.
TCR Guidelines Apply to Marketing & Promotional Messaging
The Campaign Registry (TCR) primarily regulates businesses that send bulk SMS marketing messages, account notifications, and customer alerts. These regulations require explicit opt-in and opt-out mechanisms because they involve unsolicited messages. However, our forms collect information as part of a consumer-initiated insurance request, meaning the communication is essential, not promotional.
We Are Already Compliant with TCPA
Our system fully complies with the Telephone Consumer Protection Act (TCPA), which governs how businesses can contact consumers via phone and SMS. TCPA compliance is more critical than TCR because it is a federal law, while TCR is an industry requirement imposed by carriers. Our intake process ensures that consumers explicitly consent to being contacted regarding their insurance applications, aligning with federal consumer protection standards.
Our Terms of Service Cover Communication Consent
Every user submitting an application through our system agrees to our Terms of Service and Privacy Policy, which include consent for communication from our platform, your agency, and affiliated companies. This ensures clear transparency and legal protection regarding follow-ups with applicants.
[Next Steps]
You may consider:
• Requesting clarification from your phone provider on why they are applying TCR marketing rules to a transactional insurance application process.
• Providing them with our explanation and highlighting that TCPA compliance takes precedence.
• Referring them to our Terms of Service and Privacy Policy (linked below), which outline consumer consent for necessary communication.
For full details, please review our [Terms of Service] and [Privacy Policy].