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Mobile strategy firm Revolution Messaging has jumped into the text-to-donate debate with an advisory opinion request submitted to the Federal Election Commission on Tuesday.

In June, the commission approved a text-to-donate proposal from aggregator M-Qube and Armour Media, but wireless carriers have since expressed a litany of concerns over compliance and have requested clarity from the commission before moving forward.

In its new advisory opinion request, Revolution Messaging argues that the m-Qube proposal will not enable political committees to make “widespread use of text messaging as a means of fundraising.” The mobile company wants wireless users to be able to contribute more than $50 per billing cycle to federal political committees, and it proposes that multiple federal committees share a premium short code by which they could accept donations via text.

“If the Federal Election Commission is serious about helping federal political committees take advantage of the most innovative technologies, they will consider these changes,” Revolution Messaging CEO Scott Goodstein said in a press release. Goodstein said while he’s “empathetic to the carriers concerns about liability,” the AOR seeks to “achieve a balance that protects the carriers while also fairly opens the system to the campaigns who want to utilize it.”

Revolution’s AOR calls for a sharing of digital short codes among campaigns and committees. One concern over M-Qube’s one-short-code-per -campaign model was the expense, as well as the length of time it would take to issue each individual short code.

The mobile company also wants the FEC to cut the cost of collecting text message contributions. Revolution is targeting the mobile carriers’ service fees for campaigns—40 percent rates that the company argues make text-to-donate a far less attractive method of fundraising. 

“Currently, carriers can charge a service fee of 40 percent, which is higher than the usual and normal rate for nonprofit organizations,” the company said in its press release. “In fact, purveyors of pornography and horoscopes are the types of organizations that pay up to a 40 percent service fee.”

Revolution’s model would increase the $50-per-billing-cycle and $200 per-election-cycle donation caps. The company is also prepared to shoulder the responsibility of collecting donor information to ensure FEC compliance for donors in excess of those limits. The wireless data collected would include names, addresses and employment information.

“This process will be conducted independently of the wireless carriers,” according to the company’s AOR.  

In order to obtain the requisite information from contributors, Revolution Messaging would require all contributors to submit their information through a webform. Once a text donation is received, the donor would get an affirmation statement from Revolution Messaging containing the amount of the contribution and the name of the recipient committee.

“If the contributor confirms the recipient information, a charge will be added to the contributor’s wireless bill,” the AOR reads. “Revolution Messaging and the aggregator service receive this information in real-time and will immediately assign this transaction to an individual political committee’s account based on the unique keyword.”

It’s the same method of sorting funds that the aggregator and Revolution Messaging “regularly employ with all of its customers’ funds” and the company’s request argues that it will “ensure that political contributions are properly accounted for.”   

The mobile company also asks the FEC to make clear that carriers cannot dictate which federal campaigns would be eligible to collect donations via text.

In its recent advisory opinion, CTIA asked the FEC if it could establish criteria for which federal campaigns were issued short codes. CTIA  and Armour Media did not immediately respond to requests for comment on the Revolution Messaging proposal.

Text-to-donate is up for discussion at tomorrow’s open meeting of the FEC. On the agenda for discussion are two draft advisory opinions—one based on the request submitted earlier this month by m-Qube and Armour Media, and the other in response to CTIA’s advisory opinion request from early July.

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