1. Audit Standardization for U.S. Offportal Market August , 2009

2. Audits Today: complex and slow
Agenda
Audits Today: complex and slow
Goals and Objectives: save time and money
Areas for Improvement: top 5 priorities
Next Steps: new process and test cases 2 2

3. Audits Today: complex and slow
CBP committee develops recommended set of guidelines and carrier rules for off portal mobile campaigns to ensure a better experience for the wireless subscribers
Comprised of wireless operators, aggregators, content providers, brands, ad agencies, and tech enablers.
The “Consumer Best Practices” document is created and updated regularly by the MMA and the CBP committee.
The MMA holds an annual CBP Industry forum every January to receive industry feedback and further improve the Consumer Best Practices document.
Purpose of the annual CBP Forum:
ENGAGE: Encourage the entire Mobile ecosystem to participate in the dialog regardless of MMA membership commitment or history in the mobile space.
SOLICIT: Discover and openly discuss areas of friction and avenues of growth potential in the mobile marketplace.
IMPROVE: Determine ways in which to best revise the Consumer Best Practices document to grow the mobile space and protect the consumer.
Audits Today: complex and slow
Carrier Team
Audit Team
Carrier
Carrier Team
Audit Team
Carrier
Mobile Subscriber
Business / Product
Team
Dev
Valued Add Service
Aggregator
Aggregator
Carrier Team
Audit Team
Carrier
Regulation Team
Audit Team
Regulatory Group
Mobile Subscriber 3 3

4. Goals and Objectives: save time & money
I. Objectives
1. Collect all audit criteria across tier1 carriers
2. Align all criteria with MMA standards
3. Develop a working process
II. Goals 1. Reduce administrative costs for audits
2. Increase quality and accuracy in compliance
3. Enable self service for reporting 4 4

5. Areas for Improvement: top 5 priorities
Notes:
Audits misalign with standards: There are no common test cases for certification and audits, so a content provider is unsure of how to conform.
Prioritizatiion: scoring methods vary between carriers, so it’s difficult to manage priorization for audits from all carriers at different points in time.
False positives: (see below) misinterpretation or extreme application of guidelines creates unnecessary auditing (e.g. txt HELP for HELP).
Difficult to escalate: each carrier has different contact points that can be overloaded at any point in time; we need to centralize contacts with clear steps to resolve problems.
No standards notifs: each carrier has their own format and method to inform, and it creates pain in clearly understanding the issue at hand.
Details:
Audit agencies reading the letter of the law and not the Spirit- The Audit agencies vary in interpretation of the guidelines and fail to capture the Spirit of the regulation. a) Audit guidelines not being in line with carrier specific guidelines or mma cbp’s b) “Reply stop to cancel” being required instead of “txt stop to stop” 2) Unhelpful feedback from the auditing agencies a) not identifying which guideline was violated b) not offering feedback on what will be within regulation. 3) Poor testing habits- Tend to generate more overhead a) trying to solicit ‘adult’ natured content b) testing with compromised MDNs (spend cap reached, blacklisted MDN etc…) c) Incorrect Test numbers – The number stated as Tested MDN is not correct d) Incorrect testing - Auditors not paying attention to the newly submitted amendment and testing legacy campaigns that no longer work. - Auditors not testing the campaign correctly, where an auditor does not follow the description of the service, which will ultimately result in a failed service experience. - Violations for incorrect websites whilst the correct websites were provided. 4) Multiple points of escalation. a) Various agencies will refer to each other for resolution, as opposed to the audit agency acting as the enforcer of the regulation. b) Delay with resolution, compromising the ability to close and audit. 5) Separate auditing rules and processes for each carrier a) Different guidelines, processes and penalties across carrier make it difficult for a CP to accommodate the requirements when they vary across carrier. Often in direct violation of another requirement. 6)
Areas for Improvement: top 5 priorities
Audits misalign with standards
Audit prioritization is difficult
False positives create needless work
Difficult to escalate quickly
No standard audit notif/severity 5 5

6. Next Steps: new process, unified test cases
Carrier Team
Audit Team
Carrier
Certification/Audit Test Scripts
Mobile Subscriber
Regulation Team
Audit Team
Regulatory Group
Business / Product
Team
Dev
Valued Add Service
Aggregator
Carrier Team
Audit Team
Carrier
Aggregator
Mobile Subscriber 6 6