Call centers providing aged life insurance leads with TCPA compliance

Last updated 2026-07-09

What are aged life insurance leads and why do call centers use them?

An aged lead is a consumer inquiry that nobody sold, worked, or converted the first time around. In life insurance, aggregators collect form fills from comparison sites, health portals, and social ads, then sell the freshest responses at top dollar. The leftovers sit in a database. After 30, 60, or 90 days those same records get repackaged as "aged leads" and sold again at a steep discount.

The price gap is real. Fresh life insurance leads from a real-time ping-post network run $20 to $60 per record depending on filters. Aged leads from the same or similar sources typically sell for $0.50 to $5.00 per record ^[1]. For a call center dialing hundreds of records a day, that math is hard to ignore.

But the discount exists for a reason. The consumer filled out that form weeks or months ago. Their situation may have changed. Other agents have probably called them already. And the consent they gave, if they gave any, may no longer cover your specific company dialing today. That last point is where TCPA liability lives.

Buying aged life insurance leads is not illegal by itself. The problem is operational. Most call centers never check whether the consent is still valid, whether the original lead generator named who would be calling, or whether the number now sits on the National Do Not Call Registry. Those gaps are exactly what plaintiffs' attorneys hunt for.

Why do aged leads create more TCPA risk than fresh leads?

Aged leads fail the two things the TCPA cares about, valid consent and DNC status, more often than fresh leads do, and they fail them silently. The Telephone Consumer Protection Act, 47 U.S.C. § 227, bans calls and texts made with an automatic telephone dialing system (ATDS) or a prerecorded voice to a cell phone without prior express written consent ^[2]. For telemarketing calls to numbers on the National DNC Registry, you also need an established business relationship or written consent. Both apply to aged leads.

Here's why risk compounds over time. When a consumer fills out a form on a lead gen site, they typically agree to contact from that site and, often, from a list of "marketing partners." That list may or may not name your company. The FCC's one-to-one consent rule, effective January 27, 2025, closed the loophole that let aggregators bundle broad consent for dozens of buyers ^[3]. Under the new rule, consent has to name the specific seller who will call. A lead generated before that date under the old bundled model may be legally useless for calls made after it.

Age matters for DNC too. The FTC's registry adds millions of new numbers every year ^[4]. A number that was clean when the lead was generated might be registered now. The safe harbor for DNC violations requires scrubbing against a database no more than 31 days old ^[4].

Litigation against insurance lead buyers keeps intensifying. Settlements like the UnitedHealthcare $2.5M TCPA case show what happens when a large organization loses control of its consent chain. Insurance is one of the sectors plaintiffs' attorneys watch hardest, because of the sheer volume of outbound dialing.

Statutory damages run $500 per negligent violation and $1,500 per willful violation ^[2]. Do the arithmetic. A call center working aged leads at 500 calls a day with defective consent could face $250,000 to $750,000 of exposure per day if a court agrees the ATDS definition applies and the consent is void.

What did the FCC's 2024 one-to-one consent rule actually change for insurance lead buyers?

It killed bundled consent. The FCC released its one-to-one consent order in December 2023, effective January 27, 2025 ^[3]. The order changed the TCPA's prior express written consent requirement so that consent has to identify the one specific seller who will make the call, not a category of businesses or a list of unnamed partners.

Before this rule, a lead gen form could say: "By submitting this form, you consent to be contacted by our partners regarding life insurance." That single line let aggregators sell one consent record to 10, 20, or more buyers. The FCC called it the "lead generator loophole" and closed it on purpose.

The order says consent must be "logically and topically associated" with the website where the consumer provided it ^[3]. A consumer who fills out a form on a mortgage comparison site cannot be reached under that consent by a life insurance call center, even if a buried partner list included insurance companies.

For aged lead buyers, the practical result is blunt. Any lead generated before January 27, 2025 with bundled consent language is almost certainly non-compliant for calls made today. Any lead generated after that date needs a consent record that names your company. If your vendor can't produce that documentation, you're calling without valid consent under the new framework.

The rule also requires consent before the seller contacts the consumer. Sounds obvious, but it matters for aged leads, because some lead gen flows grabbed contact info first and showed disclosures after submission. Those records are dead weight now.

Some vendors responded by building per-brand disclosure pages where the consumer picks which companies can contact them. That can produce compliant consent, but only if the consumer actually saw and acknowledged the specific company name. Ask every vendor for the exact consent language and the URL where it appeared. Then ask again.

How should call centers scrub aged life insurance leads before dialing?

Scrubbing is a recurring process with hard federal deadlines, not a one-time chore. The National Do Not Call Registry requires telemarketers to use a version of the registry no older than 31 days ^[4]. So even if you scrubbed last month, you re-scrub before dialing again. A file you plan to work over 60 or 90 days needs at least two scrub cycles before you're done.

Beyond the federal DNC, several states run their own registries. Florida, Indiana, Louisiana, Massachusetts, Mississippi, Missouri, Oklahoma, Pennsylvania, Texas, and Wyoming all maintain state DNC lists with their own registration rules ^[5]. If you dial into those states, you need separate subscriptions and separate scrubs for each.

For ATDS and prerecorded calls to cell phones, scrubbing also means confirming consent. Specifically:

1. Get the consent record from your lead vendor in writing. 2. Verify the consent language names your company, or at minimum meets the FCC's one-to-one rule for leads generated after January 27, 2025. 3. Check that the phone number on the lead matches the number in the consent record. Porting and reassignment happen constantly. 4. Run the number against the Reassigned Numbers Database maintained by the FCC, which tracks numbers disconnected and reassigned to a new consumer ^[6]. Calling a reassigned number without checking is a known litigation trigger. 5. Document every step with timestamps.

The FCC launched the Reassigned Numbers Database in 2021 because callers kept reaching people who'd inherited a recycled number and never consented to anything ^[6]. Callers who check the database and have a reasonable basis to believe the number still belongs to the consenting party get some liability protection. Callers who skip it get none.

For tools that automate DNC scrubbing and consent verification, LeadCompliant has a free DNC checker and a one-time compliance kit that covers the scrub workflow for aged lead files.

Scrub internally too. Keep your own DNC list of consumers who asked not to be called, even when their number isn't on the federal registry. The TCPA requires you to honor those requests for at least five years ^[2].

What does valid prior express written consent look like for a life insurance lead?

It's an agreement the consumer signed, in plain language, that names the seller allowed to call. The TCPA's implementing rules at 47 C.F.R. § 64.1200 define prior express written consent as an agreement that is "clear and conspicuous," carries the consumer's signature (electronic signatures count), and discloses that the person agrees to receive calls made by or on behalf of a specific seller ^[10].

For a life insurance aged lead generated after January 27, 2025, a valid consent record should include:

• The consumer's name and phone number
• A timestamp of when consent was given
• The URL of the page where consent was collected
• The exact disclosure language shown to the consumer
• The specific company name authorized to call (under the one-to-one rule)
• The consumer's IP address and any other technical identifiers the vendor captured

None of this is exotic. Reputable vendors already collect most of it. The real question is whether they'll hand it to you. If a vendor balks at providing consent documentation, that tells you what you need to know.

The paper trail decides cases. When a TCPA class action lands, plaintiffs' attorneys serve discovery for consent records on every class member. If you can produce a clean record for each number, you can usually beat individual claims even after a class gets certified. If you can't, you're settling. The Credit One TCPA settlement and the Truist Bank TCPA class action settlement both involved consent records that were incomplete or poorly kept.

One practical point. A checkbox buried at the bottom of a form in 6-point type does not meet the "clear and conspicuous" standard. Courts have thrown out consent hidden in terms-of-service links, pre-checked boxes, and fine print. Your vendor's form design matters as much as the legal language on it.

What calling rules apply beyond consent, such as hours, frequency, and identification?

Consent is necessary, not sufficient. A perfect consent record still doesn't override the TCPA's and FTC's rules on how and when you call.

Time limits are absolute. The TCPA bans telemarketing calls before 8 a.m. or after 9 p.m. local time where the called party is located ^[2]. So you need to know where the number sits, not what time it is at your desk. A call center in Arizona dialing a Florida number at 7 p.m. local time is calling at 10 p.m. Florida time. That's a violation. Use a dialer with local-time logic.

Identification applies to every call. State your name and the company you're calling for at the start. Give a phone number or address where the consumer can reach you during business hours. Prerecorded messages carry those same requirements plus an opt-out mechanism announced at the start and available throughout ^[10].

Frequency is a softer area legally, but calling the same number 15 times in a week draws complaints, and complaints pile up into class actions. Some states set hard limits. Washington State's statute, for example, bars calling the same number more than twice in any 12-month period without an established relationship ^[5].

For ATDS calls, the definition of what counts as an ATDS has been unsettled since the Supreme Court's 2021 ruling in Facebook v. Duguid ^[7]. The Court narrowed it to systems that use a random or sequential number generator. Most modern predictive dialers, which pull from a pre-loaded list instead of generating numbers, may fall outside that definition. But state laws like Florida's broader standard can pull them back in, and some courts still read the definition wide. This is a spot where you want an attorney reading your specific dialer's spec sheet.

How does the TCPA's do-not-call framework apply to aged insurance leads specifically?

The DNC framework has two moving parts, and aged leads trip on both. The first is the National Do Not Call Registry, run by the FTC. The second is the TCPA's internal DNC rule: if a consumer asks you specifically not to call, you honor that for at least five years no matter what the registry says ^[2].

For the registry, the aged-lead routine is simple. Scrub within 31 days, keep an active subscription, and log every scrub. The FTC's Telemarketing Sales Rule also covers outbound calls that involve selling, which life insurance calls almost always do ^[8]. The TSR mirrors much of the TCPA but adds its own pieces, including bans on misrepresentation and a duty to promptly disclose the purpose of the call.

The tricky part is the "established business relationship" (EBR) exemption. An EBR exists when a consumer bought, rented, or leased from your company within the past 18 months, or inquired with you within the past three months ^[4]. Most aged insurance leads don't qualify, because the consumer inquired through a third-party lead gen site, not with your company. That inquiry creates an EBR with the lead gen site. Not with you.

Some call centers assume buying the lead transfers the EBR. It doesn't. The FTC has been clear that an EBR is not a transferable commodity ^[8]. To rely on one, the consumer has to have done business with your specific company.

So for most aged life insurance leads, you have no EBR to lean on. Your only legal basis for calling a number on the DNC Registry is prior express written consent that names your company. Get that documentation from your vendor, or don't dial the number.

What do courts and settlements tell us about the actual cost of getting this wrong?

Insurance TCPA litigation is not theoretical, and cheap-lead dialing has produced some of the biggest class settlements in any industry. The UnitedHealthcare $2.5M TCPA settlement came from allegations that calls went out without adequate consent. At $500 to $1,500 per call, even a modest batch of badly dialed numbers snowballs into enormous aggregate exposure. That's why companies settle instead of litigating to verdict.

The Cash App TCPA class action settlement and the Albertsons/Safeway TCPA settlement came out of other industries, but the shape is identical. Automated or prerecorded contacts to consumers without adequate consent, scaled across thousands of records, produce class-wide liability that swamps any savings from cheap leads.

Run the numbers on a small shop. Buy aged leads at $1 each, dial 500 a day, and the economics look great until a plaintiff's attorney finds 10,000 calls made without valid consent. That's a $5 million to $15 million statutory-damages threat. Even a settlement at ten cents on the dollar costs more than your entire lead spend for the year.

Willfulness is the multiplier that ends companies. Courts have found willful violation when a caller keeps dialing after receiving DNC requests, or after being told the consent was defective. At $1,500 per call, that willful finding can triple the settlement. Congress built that multiplier in on purpose.

Nobody has clean data on what share of insurance calls draw TCPA complaints. The closest signal is the FTC's Consumer Sentinel data, where insurance-related calls consistently land among the top categories of DNC complaints year after year ^[11]. That complaint volume is what pulls class action attorneys toward the sector.

What should a call center's TCPA compliance checklist include before working any aged lead file?

This is a process question, not a legal riddle. You don't need an attorney to run a sound pre-dial checklist, though you do want one for the edge cases. Before you load any aged lead file into your dialer, run these eight steps.

Step 1: Consent documentation review. Request the consent record for every number. It should carry the consent timestamp, URL, disclosure language, and the specific company name authorized to contact the consumer. Reject any file where the vendor can't produce these.

Step 2: Date gate. If the lead was generated before January 27, 2025, judge whether the consent language meets the FCC's one-to-one standard. Bundled-consent leads from before that date are high-risk for calls today. Factor that into whether you buy at all.

Step 3: National DNC scrub. Run the file against the National Do Not Call Registry using a scrub no more than 31 days old. Log the scrub date and results.

Step 4: State DNC scrubs. Identify which states appear in the file. Run applicable state registry scrubs for Florida, Indiana, Louisiana, Massachusetts, Mississippi, Missouri, Oklahoma, Pennsylvania, Texas, Wyoming, and any other state where you operate ^[5].

Step 5: Reassigned Numbers Database check. Query the FCC's Reassigned Numbers Database for each number. Record that the query ran and what it returned ^[6].

Step 6: Internal DNC suppression. Suppress numbers on your internal do-not-call list. If you don't keep one, start today.

Step 7: Time-zone tagging. Tag each record with its local time zone before loading. Confirm your dialer enforces the 8 a.m. to 9 p.m. local-time window.

Step 8: Script and identification review. Confirm your agents' script carries the required identification disclosures, and that any prerecorded message includes a working opt-out.

For steps 3, 4, and 5, LeadCompliant's free checkers handle bulk DNC scrubs and flag numbers that need a second look. The compliance kit at LeadCompliant also includes template consent-record request letters you can send to vendors.

Document everything. Every scrub, every consent review, every suppression decision gets a timestamp and the name of who ran it. That record is your defense when a complaint arrives.

How do state laws add requirements beyond the federal TCPA for insurance lead calling?

Federal law sets a floor, not a ceiling. Several states have telemarketing and privacy statutes stricter than the TCPA, and insurance lead calling answers to all of them wherever the consumer sits.

California is the most demanding. The California Consumer Privacy Act (CCPA) gives consumers the right to opt out of the sale of their personal information, and a phone number tied to an insurance inquiry almost certainly counts as personal information ^[9]. If a California resident's data rode in on a lead file that was "sold" (a lead purchase almost always is), that consumer has CCPA opt-out rights independent of any TCPA consent. The California AG and the California Privacy Protection Agency can enforce with fines of $2,500 per unintentional violation and $7,500 per intentional one ^[9].

Florida's Telephone Solicitation Act (FTSA) went well past federal law starting in 2021. It bans calls and texts made with an auto-dialer to Florida residents without prior express written consent, using a state definition broader than the post-Duguid federal ATDS standard ^[5]. FTSA damages are $500 per call with trebling for willful violations, and it carries no class action bar. Florida plaintiffs' attorneys love it.

Texas, Indiana, and other states run their own registries and their own private rights of action. The patchwork means a national call center working aged life insurance leads has to track which state each consumer is in and apply the strictest applicable standard for that state.

Some states also regulate insurance telemarketing through their department of insurance rules, separate from general telemarketing law. If you're licensed as an insurance producer or work with licensed agents, those rules stack on top of the TCPA framework. Check your state's department of insurance requirements, not only the TCPA checklist.

For how enforcement plays out at the state level with specific attorneys and cases, the TCPA news section tracks recent developments across states.

How should call centers evaluate aged lead vendors for TCPA compliance quality?

A cheap lead from a non-compliant vendor is not cheap once you price in litigation risk. Judging vendors on compliance quality is a business decision, not a legal footnote. Ask every vendor these questions before you buy:

1. What is the exact consent language shown to consumers? Can you send the live URL where it appears? 2. Does the consent language name our specific company, or does it use a partner list or category? 3. When was this lead generated? What is the maximum age of leads in this file? 4. Do you keep a record of the consumer's IP address, timestamp, and browser session for each lead? 5. Have you scrubbed against DNC before delivering this file? What was the scrub date? 6. Do you retain consent records for at least five years? Can we audit them? 7. What indemnification do you provide if a TCPA claim comes from a lead you sold us?

Question 7 is the one most call centers skip. Indemnification agreements are worth having even when they're hard to enforce. A vendor that refuses any indemnification clause is telling you how confident they are in their own consent quality.

Reputable aged lead vendors will answer all seven without flinching. Many will hand you a sample consent record before you commit to a file. If a vendor dodges, rushes you, or can't walk through its consent flow, walk away. The margin on aged leads can't absorb even one TCPA class action threat.

Look too at how long the vendor has been in business, whether it's registered with the relevant state insurance regulators, and whether it shows up in published TCPA settlements as a co-defendant or third-party defendant. A quick search of PACER, the federal courts' public filing database, can surface that, though it's not a perfect read on compliance quality ^[12].

What does a realistic TCPA defense look like if a call center gets sued over aged insurance leads?

Most TCPA suits against insurance call centers start one of three ways. A complaint to the FTC or FCC, a plaintiff's attorney running a monitored line or TCPA tester, or a direct demand letter. The first document you see is either that demand letter or a class action complaint.

The real defenses are narrower than people expect. The main ones:

Prior express written consent. A clean record that names your company, was collected with clear disclosure, and was matched to the dialed number is your strongest defense. Courts have dismissed TCPA claims at the pleading stage when the defendant produced credible consent documentation.

Established business relationship. Useful only if the consumer actually did business with your specific company, not the lead vendor.

ATDS definition. After Facebook v. Duguid, you can argue your dialer doesn't meet the Supreme Court's narrow ATDS definition. That helps against federal claims but not against state-law claims in places like Florida that use a broader definition.

Reassigned number defense. If you checked the FCC's Reassigned Numbers Database and had a reasonable basis to believe the number still belonged to the consenting party, you have a partial defense ^[6].

What doesn't work: "I bought the leads in good faith." Good faith is not a TCPA defense. The statute imposes strict liability for most violations, so if you dialed without valid consent you're liable even if you never knew the consent was defective. That's why verifying consent before dialing matters so much more than good intentions.

Get a demand letter and take it seriously. Respond fast, preserve every record, and hire counsel who's actually handled TCPA matters. Demand letters often settle for $500 to $2,000 per claim when you move quickly and have some documentation. Ignore one and you hand the plaintiff's attorney room to file and build a class, which costs dramatically more. See how individual claims can grow into serious litigation in the Joseph Snyder v. Credit One TCPA case.

Frequently asked questions

How old is too old for an aged life insurance lead to be legally callable?

There's no statutory age limit. The legal question is whether the original consent is still valid, not how many days old the lead is. But consent ages badly: consumers forget they filled out a form, numbers get reassigned, and DNC registrations pile up. In practice, many TCPA defense attorneys treat leads over 90 days as high-risk without fresh consent verification, and leads over 180 days as presumptively non-compliant if they were generated under bundled consent.

Can I call a cell phone with an aged life insurance lead if I have a human agent dialing manually?

Yes. A human agent dialing manually without an ATDS avoids the TCPA's ban on autodialed calls to cell phones. But DNC restrictions still apply. If the number is on the National DNC Registry and you have no prior express written consent or established business relationship, you can't call it no matter how the call is placed. Manual dialing removes the ATDS exposure. It doesn't erase the DNC or consent requirements.

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

The FCC's one-to-one consent rule requires that TCPA prior express written consent name the one specific seller who will contact the consumer, not a generic list of marketing partners. It was adopted in December 2023 and took effect January 27, 2025. Under it, bundled consent forms listing dozens of unnamed companies no longer produce valid consent for any of them. Each company has to be named individually in the disclosure.

Does buying an aged lead file give me the seller's established business relationship with the consumer?

No. An established business relationship under the TCPA and FTC Telemarketing Sales Rule belongs to the company that actually had the relationship with the consumer. It doesn't transfer through a lead purchase. If you buy a lead from a comparison site or aggregator, their EBR with the consumer doesn't carry to you. To use an EBR exemption for DNC purposes, the consumer must have inquired with or done business with your specific company directly.

How often do I need to re-scrub an aged lead file against the National DNC Registry?

The safe harbor under the FTC's Telemarketing Sales Rule requires scrubbing against a version of the National DNC Registry no more than 31 days old. If you're dialing a file over a period longer than 31 days, re-scrub before you keep dialing. Log every scrub with the date it ran. Many compliance-focused dialers automate this, but you still need to confirm the scrub is actually running.

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

The FCC's Reassigned Numbers Database is a national registry of phone numbers that were permanently disconnected and reassigned to new subscribers. The FCC created it in 2021 to help callers avoid reaching unintended recipients. You aren't legally required to query it, but callers who do and have a reasonable basis to believe the consenting party still holds the number get a partial safe harbor from TCPA liability. Skipping the check is a known litigation risk.

Can I text aged life insurance leads instead of calling them?

Texting is subject to the same TCPA consent requirements as autodialed calls. An SMS sent to a cell phone using an ATDS without prior express written consent is a violation, whether you call or text. For aged leads where the original consent may be defective, texting doesn't lower your exposure, it just changes the channel. The FCC's one-to-one consent rule applies to texts as well as calls. See more on text message marketing and compliance rules.

What states have their own DNC registries that I need to scrub separately from the federal list?

As of 2025, states running their own Do Not Call registries include Florida, Indiana, Louisiana, Massachusetts, Mississippi, Missouri, Oklahoma, Pennsylvania, Texas, and Wyoming. Each has separate registration requirements, scrub processes, and in some cases a private right of action for violations. If you dial into any of these states from an aged lead file, you need a separate scrub for each state on top of the federal National DNC Registry scrub.

What records should I keep to defend a TCPA claim from an aged insurance lead call?

At minimum keep the consent record (timestamp, URL, disclosure language, consumer's name and number, your company name as listed), the DNC scrub log (date run, database version, results), the Reassigned Numbers Database query result, your internal DNC suppression file, the dialer log showing when the call was placed, and the call recording if one exists. Keep these at least five years. Courts routinely allow TCPA claims up to four years old under the discovery rule.

How does Florida's Telephone Solicitation Act differ from the TCPA for insurance lead calling?

Florida's FTSA uses a broader definition of auto-dialer than the post-Facebook v. Duguid federal ATDS standard, covering any system that can dial numbers automatically from a list, not only those using a random or sequential number generator. It requires prior express written consent for both calls and texts, with no established business relationship exemption for the technology restriction. Damages are $500 per violation with trebling available, and there's no class action bar, which makes Florida a busy state for TCPA-style litigation.

Is it legal to robocall aged life insurance leads?

Only with prior express written consent that names your company and meets the FCC's one-to-one standard. A prerecorded or artificial voice call to a cell phone without that consent is a TCPA violation carrying $500 to $1,500 per call in statutory damages. For calls to residential landlines without consent, the same prohibition applies. Prerecorded messages also require a working opt-out mechanism disclosed at the start of the message.

What should I do if a consumer on an aged lead list asks me not to call again?

Add them to your internal Do Not Call list immediately and honor that request for at least five years, as the TCPA requires. This applies even when the number isn't on the National DNC Registry. Calling again after a do-not-call request is treated as willful violation, which raises per-call damages from $500 to $1,500. Train every agent to log DNC requests in real time and confirm the suppression was applied before the call ends.

How much does TCPA consent documentation from a lead vendor actually cost?

Consent documentation itself should be free from any legitimate vendor. It's part of what you pay for when you buy the lead. Some vendors charge for enhanced compliance packages that add IP verification, session replay, or indemnification agreements. Those premium features might add $0.25 to $1.00 per record on top of the lead price. If a vendor wants to charge separately for basic consent records, treat that as a red flag about their practices.

Can a small call center with just 5-10 agents face a class action over aged insurance leads?

Yes. Class action standing under the TCPA doesn't depend on the size of the defendant. What matters is whether the same improperly obtained lead file was used to call enough people to certify a class, usually around 40 or more. A small call center that buys a file of 5,000 aged leads and dials all of them without valid consent can face a class covering all 5,000 numbers at $500 to $1,500 each. The size of your operation doesn't limit your exposure.

Sources

1. FTC, Telemarketing Sales Rule overview: Lead pricing context and the FTC's framework for what constitutes a valid consumer transaction in telemarketing
2. 47 U.S.C. § 227, Telephone Consumer Protection Act (Cornell LII): Prohibits autodialed/prerecorded calls to cell phones without prior express written consent; $500 per negligent violation, $1,500 per willful violation; 8 a.m. to 9 p.m. local time restriction; internal DNC honoring requirement of at least 5 years
3. FTC, National Do Not Call Registry information for businesses: DNC scrub must use a database no older than 31 days; EBR exemption covers purchases within 18 months or inquiries within 3 months with the specific company
4. National Conference of State Legislatures, State Telemarketing Laws: States with their own DNC registries include Florida, Indiana, Louisiana, Massachusetts, Mississippi, Missouri, Oklahoma, Pennsylvania, Texas, and Wyoming; Florida FTSA imposes broader auto-dialer definition
5. Facebook, Inc. v. Duguid, 592 U.S. 395 (2021), Supreme Court of the United States: Supreme Court narrowed ATDS definition to systems using random or sequential number generators; pre-loaded list dialers may not qualify as ATDS under federal law
6. FTC, Telemarketing Sales Rule (16 C.F.R. Part 310): TSR applies to outbound calls involving selling; EBR is not transferable between companies; prompt disclosure of call purpose required
7. California Attorney General, California Consumer Privacy Act: CCPA gives California residents right to opt out of sale of personal information; violations subject to $2,500 unintentional and $7,500 intentional fines per violation
8. 47 C.F.R. § 64.1200, FCC TCPA implementing regulations (Cornell LII): Defines prior express written consent as clear and conspicuous agreement bearing consumer's signature disclosing specific seller authorized to call; prerecorded messages must include opt-out mechanism at start
9. FTC, Consumer Sentinel Network reports (DNC complaint data): Insurance-related calls consistently rank among the top categories of DNC complaints in FTC consumer complaint data
10. PACER, Federal court public access system: Public database for searching federal case filings including TCPA class actions and settlements