The FCC is in the process of cracking down on companies that use long codes for marketing and interacting with customers. It's too amenable to fraud.
You should be using short codes which have strict requirements for opting in, opting out, and restrictions on spam.
If this is using long codes you are setting yourself up for fines and legal problems if you use this service.
There's a distinct difference between marketing/spam and customer service/support. When a customer initiates the conversation via text, it is generally seen as an assumed opt-in.
Our issue with short codes are that they are very expensive ($3000 setup fee and cost per text after that) and a 12 week approval process. That just doesn't work for our use case.
The laws definitely need to be updated though.
I've also done many text projects for small businesses using Twilio with long codes. I sincerely hope the FCC would prioritize cracking down on scamming robocallers (a major nuisance) before they crack down on small businesses attempting legitimate communication with their customers.
Now is probably not the time to be using long codes.
Not ideal of course. Best to have geographically isolated short codes to minimize this. But it's better to be FCC compliant.
http://www.usshortcodes.com/get-a-sms-short-code/sms-short-c...
I'm a pretty risk-averse person and I can't imagine in any way the FCC cracking down on the use of long codes for legitimate two way communication with an existing customer. On the other hand, using long codes for mass marketing campaigns and you'll probably be shut down by the carriers and possibly sued, no FCC action required.