What are the requirements for 10DLC Opt In Workflow?

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Non-compliant opt-in
Opt-in process not compliant or opt-in is not explicit.

I've gotten this twice now, despite what I thought was a very explicit opt in.

I've put my text below - what do I need to change to make this "compliant" and "explicit"? The lack of detail on this error is very hard to work with. I've read and copied the requirements list from the AWS page but that didn't seem to help.

My use case is stupid simple - just 2fa codes - I don't understand why it's having trouble with opt in as the rejection.


Full text of what I've currently put:

Users provide their phone number and click a button to send them a code to verify it, during account creation or editing their phone number. 

When logging in, if they have a verified phone number, users may choose to receive their 2fa code via SMS as an explicit choice in that session. 

Users are not contacted via SMS except for when they explicitly request it during that session (on the website), for verification or login codes. 

The Call to Action/Opt-in location must include the following:

Comprehensive terms and conditions will be presented in full as a link beneath the call-to-action - login or verification.

Program (brand) name - <brand info redacted>

Message frequency disclosure - messages are only sent when the user explicitly requests it during that session (on the website), for verification or login codes. 

Product description - login and verification codes for <brand> website, where players register for <events>

Customer care contact information is on our contact us page on the website and on the terms and conditions linked under the call to action. 

Opt-out information is on the user's settings page and is also linked on the terms and conditions linked under the call to action. Users may text STOP or unlink their phone number from their profile.

“Message and data rates may apply” disclosure is present under the call to action
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