Outbound dialing compliance challenges every sales team faces

Last updated 2026-07-09

What makes outbound dialing compliance so hard right now?

Outbound dialing compliance is harder in 2026 than it was five years ago, and the rules keep moving. The TCPA was written in 1991 for a world of fax machines and simple dialers. Courts and the FCC have been retrofitting it onto modern dialing technology ever since, and the fit is often ugly.

The core statute, 47 U.S.C. § 227, prohibits using an automatic telephone dialing system (ATDS) to call or text a wireless number without prior express consent ^[1]. That single sentence has generated more class-action litigation than almost any other federal consumer-protection law. Federal court dockets track TCPA filings among the most common civil case categories year after year.

Three things make this harder than it was even in 2018. The FCC's one-to-one consent rule reached its effective date, so a single consent form can no longer cover calls or texts from multiple companies at once ^[2]. Lead generators who built their business on shared-consent web forms have had to rebuild from scratch. State legislatures have stopped waiting for federal clarity. Florida, Oklahoma, Maryland, and others now run parallel mini-TCPA statutes with their own consent thresholds and their own private rights of action. And ATDS case law is still unsettled after Facebook v. Duguid (2021), where the Supreme Court narrowed the ATDS definition but left courts disagreeing on what equipment qualifies ^[3].

Here is the honest summary. A well-intentioned sales team can land in class-action territory through one vendor's bad consent practice or a single list hygiene mistake. That is why outbound dialing compliance is a board-level problem for companies that do real outbound volume.

What does the TCPA actually require for outbound calls and texts?

The TCPA sets two separate consent tiers depending on what you are doing ^[1]. Informational contact needs the lighter tier. Marketing contact to a cell phone needs the heavy one.

For calls and texts that are purely informational (not marketing), prior express consent is enough. The caller must have the called party's number in a context where giving the number implies consent to be contacted. A customer who types their cell number into a checkout form probably satisfies this standard for order-status calls.

For telemarketing calls and texts to a wireless number using an ATDS or prerecorded voice, the statute requires prior express written consent. "Written" here means something the consumer signed or electronically acknowledged, explicitly agreeing to receive autodialed or prerecorded marketing communications from that specific company, at the specific number. The statute conditions autodialed telemarketing on the "prior express written consent of the called party" ^[1]. Courts have not been forgiving when companies try to fuzz this line.

Calls to residential landlines using prerecorded voice fall under the same written-consent ban for marketing, whether or not the number is wireless. Live agent calls to residential landlines run under the FTC Telemarketing Sales Rule and the national DNC registry rather than the ATDS consent requirement, though you still need a do-not-call policy and proper identification disclosures ^[4].

Time-of-day rules apply across the board. Federal law restricts telemarketing calls to 8 a.m. through 9 p.m. in the called party's local time zone. Miss that window and you have added another claim to any lawsuit that follows. Some states run tighter windows. Florida's FTSA cuts off at 8 p.m.

If you manage both voice and text, the tcpa sms compliance rules apply the same statutory framework to a different medium, but the consent documentation practices need to be handled separately.

What is the FCC's one-to-one consent rule and who does it affect?

The FCC's one-to-one consent rule, adopted in its December 2023 Report and Order (FCC 23-107), requires that consent for autodialed or prerecorded marketing calls be obtained from one consumer by one seller at a time ^[2]. It amended the FCC's TCPA consent regulations to shut down bundled, shared-list consent.

Before this rule, lead generation websites routinely buried a paragraph in their terms that granted consent on behalf of a list of companies, sometimes dozens of them, all under one checkbox. Courts had allowed this under the theory that the consumer "consented" even if they never heard of half the companies on the list. The FCC closed that door.

Under the new rule, consent must be logically and topically associated with the website or interaction where it is collected. A consumer filling out a mortgage rate quote form can consent to calls from mortgage lenders. They cannot, through that same form, consent to calls from unrelated insurance companies just because both bought leads from the same aggregator.

Who gets hit directly? Lead buyers who purchased aged leads from shared-consent forms. Performance marketing agencies that ran multi-seller lead gen portals. Insurance, mortgage, solar, and home services verticals that built entire contact center models around those lead flows. The FCC estimated the affected industry runs roughly $1 billion per year in lead generation activity, and the commission openly acknowledged uncertainty in that figure ^[2].

The fix is simple to state and expensive to run. Every consent capture point must name your company specifically, and the consumer's assent must be visibly tied to your company's contact program. If you are buying leads, get written representations from the seller that the consent form named you individually. To track how enforcement is playing out, the tcpa news today section follows FCC actions as they come out.

How do Do Not Call list requirements work for outbound dialers?

The national DNC registry is run by the FTC and covers residential telephone numbers, including most cell numbers that consumers have registered ^[7]. Telemarketers must scrub their call lists against the registry before dialing. The registration requirement applies to any company making more than about 12 telemarketing calls per year. Access is $75 per area code per year, with up to five area codes free (check the FTC directly for current fees; they change) ^[7].

The safe harbor under 47 C.F.R. § 64.1200(c) requires that your list be scrubbed within 31 days before any call ^[8]. Scrubbing a list once and sitting on it for six months is a common mistake that turns a compliant campaign into a violation.

Beyond the federal registry, almost every state runs its own DNC list. Some states require separate registration. Some impose shorter scrub intervals. Some cover B2B calls that the federal registry explicitly excludes. The overlapping state requirements are genuinely confusing, and no single authoritative table stays current. Texas, Colorado, and Indiana have provisions that go meaningfully beyond the federal baseline.

There is also the company-specific internal DNC obligation. Under FTC rules, if a consumer tells you during a call that they do not want to be called again, you must honor that for at least five years and add them to your internal DNC list promptly. The FTC has treated 30 days as a rough outer benchmark, though the rule itself says "promptly." Missing internal DNC compliance is one of the most common violations the FTC and state AGs find when they audit a company after a complaint.

For the full picture on DNC obligations across channels, the lead generation compliance news feed covers FTC and state-level enforcement updates as they happen.

What counts as an ATDS and why does the definition matter so much?

Whether your dialer qualifies as an automatic telephone dialing system decides whether you need consent for cell phone calls at all. The TCPA defines an ATDS as equipment with the capacity to store or produce telephone numbers using a random or sequential number generator and to dial those numbers ^[1].

In Facebook v. Duguid (2021), the Supreme Court narrowed this definition, holding that a system must use a random or sequential number generator, not merely have the capacity to dial stored lists automatically ^[3]. That ruling gave many power-dialing vendors and their customers a short exhale. It did not resolve everything.

Several federal circuits still disagree on how to apply Duguid to systems that dial from uploaded lists through automated processes. Some courts have found that predictive dialers with certain features still qualify as ATDSs after Duguid. The Eleventh Circuit has been aggressive in finding ATDS status for systems that automate the dialing process even when they dial from a pre-loaded list.

Do not build your compliance program on the assumption that your dialer is not an ATDS. If you cannot get a clean legal opinion that your specific system, running your specific workflow, falls outside the Duguid definition under your jurisdiction's current case law, treat it as an ATDS and collect written consent. The cost of that assumption is more compliance friction. The cost of the wrong assumption is $500 to $1,500 per call.

Human-initiated calls, where a live agent manually dials with no predictive or automatic component, generally fall outside ATDS territory. Some teams have moved to click-to-dial systems specifically to take ATDS risk off the table. That trades away speed and scale, but for small teams working cold lists, it is sometimes the cleanest answer.

What are the real TCPA penalty ranges and how do lawsuits actually unfold?

The TCPA creates a private right of action with statutory damages of $500 per violation for negligent violations and $1,500 per violation for willful or knowing violations ^[1]. There is no cap per plaintiff, and each individual call or text is a separate violation.

That math compounds fast. A 10,000-call campaign to a bad list can theoretically produce $5 million to $15 million in statutory damages exposure before attorneys' fees. Class actions magnify this because plaintiffs' lawyers file on behalf of everyone who received the calls, not one person.

Public settlement figures give a sense of scale. Capital One settled a TCPA class action for $75.5 million in 2014. Dish Network faced a $280 million judgment in a federal telemarketing enforcement case, which is government enforcement rather than a TCPA class action but shows how far the numbers reach ^[10]. Smaller companies settle TCPA class actions regularly in the $2 million to $20 million range. The plaintiffs' bar treats TCPA litigation as a reliable income stream because the statute allows individual and class actions, and defendants often settle to avoid the uncertainty of per-call damage math.

The FCC can also pursue administrative enforcement, including fines. In recent years the FCC has issued fines against robocall operations in the hundreds of millions of dollars, though collecting from bad actors is often a different story. The FTC pursues telemarketing violators under the Telemarketing Sales Rule and FTC Act, with civil penalties up to $50,120 per violation under current penalty schedules ^[4].

For small teams, the more immediate threat is usually a single-plaintiff demand letter, not a full class action. A plaintiff's lawyer who catches one unlawful call can send a demand for $3,000 to $10,000 and often gets paid, because the alternative is expensive litigation. These nuisance settlements add up. They rarely get fixed because the team writes the check and never updates its process.

How does consent documentation work in practice, and where do teams go wrong?

Consent documentation is where most compliance failures actually start. The problem is almost never that teams intend to break the law. They build a sales process first and try to retrofit consent into it.

Prior express written consent for TCPA purposes needs five elements to hold up: (1) a clear disclosure that the consumer will receive autodialed or prerecorded calls or texts, (2) the name of the company that will be calling, (3) the consumer's phone number, (4) the consumer's affirmative agreement (not pre-checked boxes), and (5) a statement that agreeing is not a condition of purchasing anything ^[1].

Pre-checked boxes fail. Buried disclosures in 8-point font at the bottom of a 2,000-word terms page fail in practice even when courts occasionally accept them. Consent collected by a third party without assigning it to your specific company fails under the FCC's one-to-one rule.

The second common failure is not keeping the evidence. You need to prove consent, more than assert it. That means storing the timestamp, IP address, form version, and verbatim consent language for every record you contact. If you use a third-party consent platform, get their data retention policies in writing and make sure they cover your litigation hold period, which in TCPA cases is typically the four-year statute of limitations.

Opt-out handling is the third gap. When someone says stop, process it fast. The FCC reads the TCPA to require that opt-out requests for texts be honored within a "reasonable" time. Many carriers treat 10 business days as a practical threshold, but the safer internal standard is 24 to 48 hours. An opt-out sitting in someone's inbox over a weekend while your automated system fires two more messages is the exact scenario that generates five-figure demand letters.

For teams building compliant SMS consent flows from scratch, the sms opt in and sms double opt in resources lay out the mechanics.

What state laws add requirements on top of the federal baseline?

State law is where outbound dialing compliance gets genuinely complicated. The rules are not uniform, and they change fast.

Florida's Telephone Solicitation Act (FTSA), expanded in 2021, created a state-level private right of action for calls and texts made using an autodialer to Florida numbers without written consent ^[9]. The FTSA defines an autodialer more broadly than post-Duguid federal interpretations and adds a narrower calling window (8 a.m. to 8 p.m.) plus a cure period before litigation. Florida saw an explosion of single-plaintiff FTSA suits in 2022 and 2023 before a 2023 amendment added a pre-suit notice requirement to slow the wave. Florida remains a high-risk jurisdiction.

Texas runs a state DNC list and provisions in the Texas Business and Commerce Code that mirror and in some places exceed TCPA requirements. Oklahoma enacted the Oklahoma Telephone Solicitation Act in 2022 with its own autodialer definition. Maryland's telephone solicitation rules carry their own registration and disclosure requirements.

California adds a separate layer through the CCPA/CPRA. The CCPA is primarily a data privacy law rather than a call-restriction statute, but it reaches outbound dialing by requiring disclosure of data collection practices, honoring opt-out-of-sale requests (which can affect third-party lead purchases), and keeping records of consumer consent for personal data use ^[5]. A company that buys leads from a California consumer database without meeting CCPA data handling requirements faces both CPRA enforcement and potential FTC action for unfair or deceptive practices.

Washington State runs a Commercial Electronic Mail Act that some courts have applied to text messages, and its Consumer Protection Act allows private actions. New York, Illinois, and Michigan are watching Florida's litigation wave and have proposed or are weighing similar state autodialer bills.

The practical answer for a small team is a state-by-state calling policy. Apply the most restrictive applicable rule to any given number (usually Florida or Oklahoma for those states), and review state law changes at least quarterly.

How should a small outbound team structure its compliance process day to day?

Most small teams do not need a compliance department. They need a process that runs automatically and a document trail that proves it ran.

Start with the list. Every list that enters your dialer should pass through a DNC scrub (national registry plus any applicable state registries) before the first call, and that scrub should be dated. If your campaign runs longer than 31 days, scrub again. Append wireless carrier data to flag cell versus landline if your consent practices differ by number type. Verify that the consent documentation in your CRM matches the record you are dialing. If you cannot find documented consent for a cell number and you are using a predictive dialer, do not call it.

Build your opt-out workflow into the dialer itself, not into a downstream manual process. When someone says stop, that record should be suppressed within the same business day. Audit that suppression quarterly by pulling a sample of opt-out requests and checking whether those numbers received any later contact.

For teams running high-volume SMS alongside voice, the sms opt in form structure is worth getting right from day one, because consent documentation failures on text campaigns are often the first thing auditors and plaintiffs' lawyers look for.

LeadCompliant's free compliance tools include a DNC number checker and a consent audit checklist built for small teams who cannot afford full-time legal counsel but need a repeatable process. One pass with a pre-built compliance kit at the start of a new campaign can catch the most common exposure points before they turn into demand letters.

Document every policy decision, even the obvious ones. If you decide to apply Florida's calling window to all numbers because it is simpler to manage, write that down. If you get sued, a conscious, documented compliance decision is evidence of good faith that courts consider when deciding whether violations were "willful" for purposes of trebled damages.

What are the biggest compliance mistakes that lead to lawsuits?

Across publicly filed TCPA complaints and consent decrees, the same mistakes show up over and over. Here are the ones that generate the most litigation.

Calling reassigned numbers is a major source of liability. Wireless numbers get recycled. The person who gave you consent two years ago may no longer own that number, and the person who received your call never consented to anything. The FCC created a Reassigned Numbers Database (RND) that carriers report to, and callers can query it to identify numbers that have changed hands ^[6]. Using the RND is not legally required, but it is strong evidence of reasonable practices in a lawsuit. Not using it when the tool exists is increasingly hard to defend.

Relying on third-party consent without verifying it. If you buy a lead list and the consent form used to collect those leads did not specifically name your company (an especially sharp point after the one-to-one rule took effect), you do not have TCPA-compliant consent. The FCC has consistently held that the burden of proving consent falls on the caller, not the consumer.

Treating soft opt-ins as marketing consent. Signing up for a webinar, downloading a whitepaper, or submitting a contact form that says "we may reach out to you" does not amount to prior express written consent for autodialed marketing calls. Courts have repeatedly rejected these broad readings.

Not training the people making the calls. A live agent who ignores a consumer's verbal do-not-call request, or who does not identify themselves and their company promptly as the TSR requires ^[4], creates liability that your documentation cannot fix after the fact.

Using a vendor without an indemnification clause. If your dialer vendor or list vendor creates a TCPA violation, you need a contract provision that lets you recover costs from them. Without it, you are jointly and severally liable and alone on the legal bills.

How do compliance requirements differ for B2B versus B2C outbound calling?

The TCPA is largely focused on protecting residential subscribers and wireless numbers, and the FTC's national DNC registry explicitly exempts B2B calls from its rules. That gives B2B teams meaningfully more room, but the exemptions are narrower than most people assume.

If you are calling a business cell phone, the TCPA wireless consent requirement still applies when the number is a personal cell used for business, which describes most cell phones. The fact that the person is a business contact does not strip the wireless number of TCPA protection. Courts have generally held that the classification of a number as wireless or residential is what triggers protection, not the purpose of the call.

The TSR's B2B exemption is real. You do not need to scrub against the national DNC registry when calling businesses at their business numbers. But state law varies. Some states extend their DNC protections more broadly. And if you are calling sole proprietors or home-based businesses, courts have sometimes applied residential TCPA protections anyway.

For B2B teams, the bigger risks tend to be the Telemarketing Sales Rule's disclosure requirements, overseas call center restrictions, and the CCPA's data handling rules when your prospecting data comes from brokers who collected consumer information ^[5]. The b2b lead generation platforms gdpr compliance piece is worth reading if any of your target prospects are EU-based, since GDPR's consent requirements for cold outreach are far stricter than U.S. law.

The short version: B2B calling is easier than B2C, but it is not a compliance-free zone. Wireless numbers, state laws, and the TSR still apply in ways that matter.

What tools and processes actually reduce outbound dialing compliance risk?

The compliance tool market has gotten crowded, and a lot of what is sold is either duplicative or underbuilt. Here is what actually matters.

A DNC scrubbing service that queries the national registry, your state registries, and your internal suppression list in a single pass before each campaign upload. Prices run from roughly $0.001 to $0.005 per record for real-time scrubbing through services like Gryphon Networks, Contact Center Compliance (formerly DNC.com), or Telnyx's compliance API. Per-record cost varies by volume and contract, so get quotes from at least two vendors before committing.

A consent management platform that timestamps and stores consent records with the form version and IP address. OneTrust and several TCPA-specific vendors offer this. For small teams, a well-structured database field in your CRM plus a file export of the original form HTML gets you 80% of the compliance value at a fraction of the cost.

The FCC's Reassigned Numbers Database, which carriers populate monthly. Querying the RND before calling a list you have not refreshed in 90 days costs a fraction of a cent per query and meaningfully reduces reassigned-number risk ^[6].

Call recording and tagging for consent verification. If a prospect gives verbal consent during a call to receive future contact, record it, tag it, and store it with the record. Some states require two-party consent for recording, so check your state's rules before you turn this on.

For SMS-heavy operations, a compliant messaging platform that automatically handles STOP, HELP, and carrier compliance templates is not optional. The marketing text message service and text message marketing software comparisons cover what to require in your vendor evaluation.

Nobody has clean data on what share of TCPA suits are prevented by good tooling versus good consent practices. The closest read from public consent decrees is that process failures, not tool failures, show up as the root cause in most FTC and FCC enforcement actions. The best tool is a written compliance policy that people actually follow.

Frequently asked questions

What is prior express written consent under the TCPA?

Prior express written consent means the consumer signed or electronically agreed, specifically authorizing your company to send autodialed or prerecorded marketing calls or texts to their number. It must name your company, disclose the autodialed nature of the communications, include the consumer's phone number, and state that agreeing is not required to make a purchase. Pre-checked boxes and buried terms do not satisfy this standard.

Can I call a cell phone without consent if I use a live agent instead of an autodialer?

If a live agent manually dials the number with no automated component, the TCPA's ATDS consent requirement does not apply to that call. The FTC's Telemarketing Sales Rule still applies, including time-of-day restrictions and do-not-call obligations. You must also honor any DNC registry listings and your internal suppression list. Some states impose additional restrictions on live agent calls regardless of technology.

How often do I need to scrub my list against the national DNC registry?

Federal rules require that your call list be scrubbed against the national DNC registry within 31 days before any call. If your campaign runs longer than 31 days, you must re-scrub. Some states impose shorter intervals. Running a single scrub at campaign launch and assuming it covers a months-long campaign is one of the most common compliance mistakes that creates retroactive liability.

Does the TCPA apply to text messages as well as voice calls?

Yes. The FCC has consistently interpreted the TCPA to cover text messages sent via an ATDS to wireless numbers. The same prior express written consent requirement applies to autodialed marketing texts. Opt-out requests sent via text (STOP replies) must be honored promptly. For the full framework, the TCPA's text rules are covered in detail in our TCPA SMS compliance guide.

What is the FCC's one-to-one consent rule and when did it take effect?

The FCC's one-to-one consent rule, from its December 2023 Report and Order (FCC 23-107), took effect in 2025. It requires that consent for autodialed or prerecorded marketing calls be collected on a one-consumer, one-company basis. Shared consent forms naming multiple companies in a single checkbox no longer satisfy the TCPA. Lead buyers must ensure their consent forms specifically named their company at the time the consumer agreed.

How much can a TCPA lawsuit actually cost a small company?

Statutory damages run $500 per negligent violation and $1,500 per willful violation, with each call or text counting separately. A campaign of 10,000 calls to a non-consenting list creates theoretical exposure of $5 million to $15 million. In practice, most small-company TCPA disputes settle in the $10,000 to $500,000 range depending on class size and call volume, but even nuisance demand letters for single violations typically seek $3,000 to $10,000.

What is the Reassigned Numbers Database and do I have to use it?

The FCC's Reassigned Numbers Database (RND) is a registry that phone carriers populate monthly with numbers that have been disconnected and reassigned to new subscribers. Using it is not legally required, but querying it before calling aged lists is strong evidence of reasonable compliance practices. Courts and the FCC consider it a known available safeguard, so ignoring it when you have a reassigned-number problem is increasingly hard to defend.

Are B2B outbound calls exempt from TCPA and DNC rules?

The FTC's national DNC registry does not cover calls to business numbers, and the TSR has a B2B exemption for certain calls. But if your B2B prospects use personal cell phones, those wireless numbers carry TCPA protection regardless of how the call is characterized. State DNC lists and CCPA data rules also apply in ways that can reach B2B activity. B2B is lower risk than B2C but not compliance-free.

What calling hours does federal law require for outbound telemarketing?

Federal law under the TCPA and TSR restricts telemarketing calls to 8 a.m. through 9 p.m. in the called party's local time zone. Some states are stricter: Florida limits calls to 8 a.m. through 8 p.m. under the FTSA. Calls outside the permitted window are independent violations on top of any consent failures. Your dialer should be configured to block calls based on the destination number's area code, not your office's time zone.

What do I need to disclose at the start of an outbound call to comply with the TSR?

The FTC's Telemarketing Sales Rule requires that the caller promptly disclose: the name of the individual caller, the company on whose behalf the call is made, and the purpose of the call. This must come before any sales pitch. Abandoning calls (hanging up without connecting to an agent) beyond a 3% abandonment rate triggers additional TSR obligations including playing a recorded message with the company name and callback number.

How does Florida's FTSA differ from the federal TCPA?

Florida's Telephone Solicitation Act defines "automated system" more broadly than the post-Duguid federal ATDS definition, covering more dialing technology. It restricts calls to 8 a.m. through 8 p.m. (versus federal 9 p.m.), creates a state private right of action with damages up to $500 per call, and since 2023 requires a pre-suit notice period before litigation can proceed. Florida is consistently the highest-litigation state for outbound dialing compliance suits.

What happens if I bought leads and the consent form did not name my company specifically?

Since the FCC's one-to-one consent rule took effect in 2025, consent collected on a form that did not specifically name your company does not satisfy TCPA written consent requirements for autodialed marketing calls. Calling those records with an ATDS exposes you to $500 to $1,500 per call in statutory damages. Your options are to get re-consent directly from each lead naming your company, or to reach those leads via methods that do not require TCPA written consent.

How long do I have to process an opt-out request from a consumer?

The TCPA and FCC rules require opt-out requests to be honored within a "reasonable" time. For SMS opt-outs, carriers and the FCC treat 10 business days as a working benchmark, but most compliant teams target 24 to 48 hours. For internal DNC requests made verbally during a call, the FTC has treated 30 days as a reasonable outside limit. Processing opt-outs slowly while your automated system continues sending messages is a common source of additional per-message violations.

What records should I keep to defend a TCPA claim?

At minimum, you need: the original consent form text and version used, the timestamp and IP address of each consent submission, your DNC scrub logs with dates, your internal suppression list and opt-out processing timestamps, and call records showing date, time, and number dialed. The TCPA has a four-year statute of limitations, so records should be retained for at least four years. If litigation starts, preserve everything immediately under a litigation hold.

Sources

1. U.S. Code, 47 U.S.C. § 227 (TCPA text): TCPA prohibits ATDS calls to wireless numbers without prior express consent; statutory damages are $500 (negligent) and $1,500 (willful) per violation; prior express written consent required for autodialed telemarketing.
2. U.S. Supreme Court, Facebook, Inc. v. Duguid, 592 U.S. 395 (2021): Supreme Court narrowed ATDS definition to require use of random or sequential number generator, not merely automatic dialing from stored lists.
3. FTC, Telemarketing Sales Rule (16 C.F.R. Part 310): TSR governs national DNC registry scrub requirements, B2B exemptions, calling hour restrictions (8 a.m. to 9 p.m.), prompt disclosure requirements, and civil penalties up to $50,120 per violation.
4. California Attorney General, California Consumer Privacy Act (CCPA) Resources: CCPA/CPRA requires disclosure of data collection practices and honoring opt-out-of-sale requests, affecting outbound lead purchases involving California consumers.
5. FTC, National Do Not Call Registry: Telemarketers must register and scrub call lists against the national DNC registry; registration is $75 per area code per year with up to five area codes available at no cost.
6. FCC, 47 C.F.R. § 64.1200 (TCPA implementing regulations): FCC regulations require DNC list scrub within 31 days before any call; define time-of-day restrictions as 8 a.m. to 9 p.m. called party's local time; specify safe harbor conditions.
7. Florida Legislature, Florida Telephone Solicitation Act (FTSA), F.S. § 501.059: FTSA restricts automated calls and texts to 8 a.m. through 8 p.m., defines autodialer broadly, creates private right of action with damages up to $500 per call, and since 2023 requires pre-suit notice.
8. U.S. Department of Justice, United States v. Dish Network (telemarketing enforcement): Dish Network faced a $280 million federal judgment for telemarketing rule violations, illustrating the scale of government enforcement in the outbound dialing space.
9. FTC, Complying with the Telemarketing Sales Rule: FTC business guidance on TSR obligations including disclosure requirements, abandonment rate rules (3% threshold), and B2B call exemptions.