SMS Compliance Architecture

Mendworthy is a B2B transactional-SMS platform delivering payment-failure notifications on behalf of subscription merchants. Consent flows through five explicit stages:

1. 1

   Subscriber→Merchant

   Subscriber provides phone number with explicit, separate, optional SMS consent at the merchant's signup. TCPA-aligned consent collection is the merchant's responsibility (principles below).

2. 2

   Merchant→Mendworthy

   Platform attestation. Merchant flips an opt-in toggle in settings; persists smsConsentAttested + evidence trail (timestamp, surface, attesting user) on their workspace record.

3. 3

   Merchant→Twilio

   Carrier verification.Merchant completes per-merchant toll-free verification through Twilio's Compliance Embeddable, supplying their own business identity, opt-in evidence, and message sample. Carriers approve each number independently.

4. 4

   Mendworthy→Twilio

   Both gates checked at send time. No code path bypasses them; merchants missing either run email-only.

5. 5

   Twilio→Subscriber

   Twilio delivers from the merchant's verified number. STOP honored platform-wide; opt-outs don't affect the subscription.

A default-unchecked attestation toggle in the merchant's settings (app.mendworthy.com/settings/sms) persists smsConsentAttested = true on the workspace record plus a TCPA evidence trail — attestation timestamp, attesting user, and surface (settings / api / onboarding) — frozen at the off → on transition. The evidence trail survives subsequent toggle cycles as audit trail on every end-customer record onboarded while attestation was active. Merchants who decline keep SMS off and run email-only recovery.

Per-merchant Toll-Free Verification through Twilio's Compliance Embeddable, hosted inside the merchant's dashboard at app.mendworthy.com/settings/sms-onboarding. Each merchant supplies their own business identity (legal name, EIN, address), website, opt-in evidence, sample production message, and monthly volume estimate. The submission goes directly from the embeddable to Twilio; Mendworthy stores only the resulting inquiry status on a merchant_tfv_submissions row. Until carrier approval lands (typically 3 business days), SMS sends are unconditionally suppressed for that merchant.

Mendworthy operates as the umbrella ISV on Twilio Trust Hub: our primary Customer Profile sits at the platform layer, and each merchant gets a secondary profile carrying their own end-business identity. That's the architecture Twilio documents for SaaS platforms sending on behalf of merchants.

Both gates evaluated at every send attempt: platform attestation (client.smsConsentAttested), subscriber STOP record (!contact.smsOptedOutAt), and per-merchant carrier-verification status (merchant_tfv_submissions.status === "approved"). Any one failing → email-only.

const smsEligible =
  sequenceAllowsSmsAtStep(dunning.sequenceType, dunning.currentStep) &&
  !merchantDisabled &&
  contact.phone &&
  client.smsConsentAttested &&
  !contact.smsOptedOutAt;

return {
  kind: "send",
  plan: {
    /* ... */
    smsScheduledAt: smsEligible ? new Date(Date.now() + SMS_STAGGER_MS) : null,
  },
};

Merchants are responsible for their subscriber consent collection. The platform attestation is the contractual mechanism for accepting that responsibility, and requires consent collection to follow standard TCPA / CTIA principles:

Explicit

SMS consent is requested distinctly from terms-of-service and privacy-policy acceptance, not bundled into a single “I agree” checkbox.

Separate

The SMS opt-in is its own choice rather than a precondition for any other agreement.

Optional

Subscribers can complete signup without opting into SMS. SMS consent is not a condition of using the merchant’s service.

Clearly disclosed

The opt-in surface communicates message frequency, the STOP keyword, and that standard message and data rates may apply.

Every SMS: merchant name, brief notice, secure card-update link, opt-out instruction.

AcmeCorp: It looks like your card on file has expired. Please update your card.

mendworthy.com/s/abc123

Reply STOP to opt out.

The subscriber-facing SMS Program Terms live at mendworthy.com/sms-consent. They cover what the SMS is, how to opt out, and how the merchant relationship works. Phone-number handling, data sharing, and retention are described in our Privacy Policy.

Questions about this architecture or our compliance posture can be directed to [email protected].