Does BatchLeads have a DNC registry scrub built in?

BatchLeads has some DNC tools, but gaps remain. Here's what it actually does, where it falls short, and how to stay TCPA-compliant. A practical guide.

LeadCompliant Team
22 min read
In This Article

Last updated 2026-07-09

Person reviewing phone list spreadsheets at a desk with DNC compliance concerns
Person reviewing phone list spreadsheets at a desk with DNC compliance concerns

TL;DR

BatchLeads includes a built-in DNC scrub that checks numbers against the federal National Do Not Call Registry before you dial or text. It is not a full compliance solution. You still manage your own company DNC list, honor state registries, and get consent for cell numbers under the TCPA. Treat the scrub as a first filter, not the last word.

What DNC scrubbing does BatchLeads actually offer?

BatchLeads runs phone numbers against the federal National Do Not Call Registry maintained by the FTC. When you pull a skip-traced list inside the platform, it flags numbers registered on the federal registry before you export or dial. That is the core of what it does. Nothing more, nothing hidden.

Why the feature matters: calling a registered number without a prior business relationship or written consent can cost you up to $51,744 per violation under the FTC's 2024 inflation-adjusted Telemarketing Sales Rule penalties [1]. Even a list of 50 numbers can grow into millions in statutory damages once a class action gets certified.

Here is the honest picture. BatchLeads' DNC scrub is a convenience layer sitting on top of a real estate investor workflow tool. It is not a standalone compliance platform. The company has not published detailed technical documentation on how often its registry data refreshes or what happens when the FTC updates the database. That gap matters, because the FTC's data changes constantly and stale data is not a safe harbor.

Running high-volume outbound for a wholesaling business? The feature cuts obvious risk. Running a licensed brokerage with real legal exposure? Treat it as a first filter, not a final one.

How does the federal Do Not Call Registry work and why does it matter here?

The National Do Not Call Registry is run by the FTC under the Telephone Consumer Protection Act (47 U.S.C. § 227) and the FTC's Telemarketing Sales Rule [2]. Consumers register their numbers for free at donotcall.gov, and registrations are permanent. The FTC stopped removing numbers after 31 days years ago. Once you are on the list, you stay on the list.

As of 2023, the registry held over 244 million registered numbers [3]. That covers a huge slice of any real estate skip-trace list you pull.

Sellers and telemarketers cannot call registered numbers unless they have an established business relationship with the consumer or the consumer gave written consent [2]. That relationship expires 18 months after the last purchase, or 3 months after a consumer inquiry. Those windows are shorter than most wholesalers assume.

The core private right of action lives in the statute. 47 U.S.C. § 227(c)(5) says a person who has received more than one call within any 12-month period "by or on behalf of the same entity in violation of the regulations" may sue and recover actual damages or $500 per violation, whichever is greater, and up to three times that for willful violations [2].

That private right of action is why TCPA suits are everywhere. Plaintiffs do not need the government to act. They sue you directly. A single class action can aggregate thousands of calls into one case, and the math gets ugly fast.

For more on how the registry works, see our guide on the do not call list.

Does BatchLeads scrub state Do Not Call lists too?

Generally no, and this is where most users get burned. The federal registry is the floor, not the ceiling. Twelve states run their own Do Not Call registries with rules that go past the federal ones [4]. Florida, Indiana, Pennsylvania, Texas, Oklahoma, Wyoming, Louisiana, Mississippi, Missouri, Montana, Oregon, and Tennessee all maintain state-level lists.

Some of these state lists cover ground the federal registry never touches. Florida's Do Not Call law applies to purely intrastate calls and reaches some business-to-business calls under certain conditions. See our breakdown of the Florida do not call list and the Indiana do not call list for the state-specific rules.

As of the time this article was researched, BatchLeads does not scrub against all twelve state registries. Its documentation points at the federal registry. If your leads cluster in Florida or Pennsylvania, that gap is real money. You would pull those state lists separately and run your own scrub before dialing.

Here is what BatchLeads covers versus what you may need to add:

Registry TypeBatchLeads Scrub?Notes
Federal DNC (FTC)YesCore feature, check refresh frequency
State DNC lists (FL, IN, PA, etc.)No (generally)Must be done separately
Your internal company DNC listPartialYou manage additions manually
Wireless/cellular TCPA restrictionsNoSeparate legal requirement entirely
Litigator listsNoThird-party add-on required

For Pennsylvania specifically, our do not call list PA article walks through the state process.

Key TCPA and DNC numbers every outbound team should know Statutory thresholds, registry scale, and timing rules 244M DNC-registered numbers (202… 1,500 Max TCPA penalty per willful violation 52k Max FTC TSR civil penalty per violation (2024) 30 Days to honor internal DNC request (TSR) Source: FTC National DNC Registry Data Book FY2023; 47 U.S.C. § 227; FTC TSR 16 C.F.R. § 310

What is a company-specific DNC list and does BatchLeads manage that?

The FTC's Telemarketing Sales Rule at 16 C.F.R. § 310.4(b)(1)(iii) requires telemarketers to keep their own internal Do Not Call list. When a consumer tells you not to call again, you add them to that list and honor the request within 30 days [5]. You keep those records for 5 years. No exceptions for small teams.

BatchLeads has a basic suppression list feature where you tag or exclude contacts. It is not built for FTC or TCPA internal DNC compliance, so you have to handle it carefully and document your process. The platform is a lead generation and skip-tracing tool at its core. The DNC features are secondary to that job.

Here is how it plays out in practice. Your team calls, someone says stop, and that number needs to hit a suppression file right away, sync back to BatchLeads, and get checked against every future list pull. A manual process works if your team is disciplined. Most small outbound teams are not that disciplined. That slippage is where TCPA suits start.

The safe move: keep your master internal DNC list in a spreadsheet or CRM that is your system of record, and push it into BatchLeads as a suppression import before every campaign. Treat the tool as the dialer interface, not the compliance database.

Are wireless numbers handled differently under TCPA, and how does BatchLeads relate to that?

Yes, and this is the highest-risk area for real estate outbound teams. Under 47 U.S.C. § 227(b)(1)(A), it is unlawful to call any number assigned to a cellular service using an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice without the prior express consent of the called party [2]. The DNC registry is irrelevant here. The restriction applies whether or not the number is registered.

Wholesalers and investors often run software that can auto-dial or blast batch texts. If BatchLeads or any dialer connected to it meets the definition of an ATDS, every outbound call or text to a cell number without consent is a potential violation. The definition has been fought over in court for years. In Facebook v. Duguid (2021), the Supreme Court held that a system must use "a random or sequential number generator" to qualify as an ATDS [6]. That narrowed things, but predictive dialers and plenty of modern outbound tools still carry risk depending on how they are built.

BatchLeads is a data and skip-tracing platform first. Whether the dialers you plug into it count as an ATDS depends on the specific dialer, not on BatchLeads. But the data you export and feed into those dialers is your liability. The mobile phone do not call list article covers this in more depth.

The DNC scrub in BatchLeads does not solve your wireless consent problem. Consent is a separate obligation, and it requires an actual opt-in from the consumer.

What are the real penalties for getting this wrong?

The FCC adjusts TCPA statutory damages for inflation. The per-violation penalty for unsolicited calls or texts to a wireless number using an ATDS is up to $500, trebled to $1,500 for willful violations [1]. There is no per-plaintiff cap in most cases, and class actions bundle thousands of calls together.

The FTC pursues its own enforcement under the Telemarketing Sales Rule. FTC civil penalties for TSR violations hit $51,744 per violation as of the 2024 adjustment [1]. Different statute, but both can apply to the same conduct depending on what you did.

Real TCPA class action settlements for mid-size companies routinely land between $1 million and $30 million. Some run higher. The scale is not theoretical, and plaintiff attorneys file these cases for a living.

Nobody has clean data on how often small real estate outbound teams get sued versus just receiving demand letters that settle quietly. The closest proxy is the FTC's DNC complaint volume, which logged 3.5 million complaints in fiscal year 2023 [3]. Not every complaint becomes a suit. But each one is a paper trail that can support a private action later.

For a fuller look at the penalty structure, our DNC registry page breaks it down.

How do you check if a number is on the Do Not Call list outside of BatchLeads?

The FTC gives telemarketers direct access to the National DNC Registry once you register at donotcall.gov [7]. You can query up to five area codes for free each year, and you pay per area code beyond that. The fee was $79 per area code per year as of 2024, though the FTC updates pricing periodically.

The common workflow outside BatchLeads: export your raw list, run it through the FTC's registry download (a flat file of registered numbers by area code), then de-duplicate. Some compliance vendors automate this against a daily feed so you never touch a spreadsheet.

For the exact steps to access the registry, our guide on how to get the do not call list walks through the process.

Third-party DNC scrubbing services like DNC.com, Gryphon Networks, and Contact Center Compliance (often called C3) charge by volume and also include litigator lists, which flag numbers tied to serial TCPA plaintiffs and their attorneys. BatchLeads does not include litigator list scrubbing. For high-volume teams, that omission carries real risk. Serial litigants file a disproportionate share of TCPA suits relative to how few of them there are.

What is a litigator list and should you use one?

A litigator list is a database of phone numbers tied to people who have filed or threatened TCPA lawsuits, plus their attorneys. These are not government lists. Private data companies build them from court records, complaint filings, and known plaintiff attorney contact information.

Scrubbing against a litigator list does not make you legally compliant. It lowers the odds that the person you call happens to be someone who sues over TCPA violations for a living. It is a risk management tool, nothing more.

For most small teams doing under 500 dials a day, a litigator list scrub is probably overkill unless you are operating in high-litigation states like California, Florida, or New York. For larger operations, the nominal per-record cost is worth it.

BatchLeads does not offer this as an in-platform feature. You would export your list, run it through a service like DNC.com or Contact Center Compliance, then re-import the cleaned list before you dial.

How often does BatchLeads refresh its DNC data?

BatchLeads has not answered this with specific public documentation, at least not in any technical disclosure I could find while writing this. That uncertainty is the whole problem.

The FTC updates the National DNC Registry continuously as new registrations come in. Telemarketers are required to download updated data no more than 31 days before making calls. If BatchLeads pulls registry data monthly or less often, there is a window where newly registered numbers look clean in the platform but are actually protected. Call one of those and the tool did not save you.

Here is the practical advice. If you are doing high-stakes outbound, do not assume any third-party tool's DNC data is current. Pull your own FTC registry download for your active area codes within 30 days of each campaign. That 30-day rule is a regulatory requirement, not a nice-to-have.

You can register for access and download the data directly at donotcall.gov [7]. Setup takes about 15 minutes, and the downloads are manageable files for most list sizes.

What should a real estate outbound team do to stay compliant beyond BatchLeads?

BatchLeads is a useful tool for finding and organizing real estate leads. It is not a compliance stack. Here is what a reasonable compliance process looks like for a small outbound team that uses it.

First, keep your own internal DNC list in a system you fully control. Every time someone asks not to be called, that number goes on the list within 24 hours, not 30 days. The regulatory deadline is 30 days. You want buffer.

Second, download a fresh FTC registry file for your target area codes within 30 days before each campaign. Merge it with your internal DNC list to build a master suppression file. Import that file back into BatchLeads before you dial.

Third, if you are texting or calling cell phones in volume, audit whether your dialer counts as an ATDS under current case law and whether you have valid consent for wireless contacts. Our government do not call list resource explains what counts as federal authority and what does not.

Fourth, check the state registries for any state where you run meaningful volume. Florida and Pennsylvania enforce actively, and the fines from state attorneys general are real. The FTC do not call list article covers federal versus state jurisdiction in more detail.

Fifth, train your callers. The most common TCPA exposure for small teams is not the technology. It is a caller who forgets to add someone to the DNC list after being told to stop.

If you want a structured starting point, LeadCompliant offers a free one-time compliance kit with a template internal DNC policy and an outbound campaign checklist. It covers the gap between what BatchLeads provides and what the regulations actually require.

For a broader look at your DNC obligations as a telemarketer, see our guide on the do not call telemarketer list.

Can BatchLeads users report DNC violations or check if a number has complaints?

No. BatchLeads does not show whether a specific number has been the subject of DNC complaints filed with the FTC. That data is not publicly searchable at the individual number level. The FTC publishes aggregate complaint data but offers no lookup by phone number for the public or for businesses.

If you receive a complaint or a demand letter claiming you called a registered number, you can look up whether that number was on the registry at the time of the call through the FTC's registry system, if you have account access. That is about the limit of the lookup functionality.

To report a number you believe violated DNC rules against you, the FTC takes reports at donotcall.gov [8]. That is a consumer tool, not a business compliance tool.

Our do not call list report article walks through how the complaint process works and what happens after a report is filed.

Is BatchLeads' DNC scrub enough on its own, or do you need more?

The honest answer: BatchLeads' DNC scrub cuts your obvious federal registry exposure, which is the most common way outbound teams get in trouble. For a small wholesaling operation making a few hundred calls a week in states without aggressive DNC registries, it probably covers the biggest risks.

It is not enough if you are texting cell phones at volume, operating in Florida, Indiana, Pennsylvania, or other states with independent registries, running ringless voicemail, or big enough that a class action would be worth a plaintiff attorney's time to file.

The gap between what BatchLeads does and what full compliance looks like is real, and it is bridgeable. It does not need expensive software. It needs discipline, a maintained internal DNC list, periodic FTC registry downloads, and caller training. Those are process problems, not technology problems. BatchLeads is not the tool to solve them, and it does not claim to be.

Frequently asked questions

Does BatchLeads scrub against the National Do Not Call Registry?

Yes. BatchLeads includes a built-in DNC scrub that checks numbers against the federal National Do Not Call Registry maintained by the FTC. It flags registered numbers during the skip-trace or list-pull process. The catch is that BatchLeads has not published specifics on how often that registry data refreshes, so you should not rely on it as your sole compliance check for regulated outbound.

Does BatchLeads scrub state Do Not Call lists?

Generally no. BatchLeads focuses on the federal registry. Twelve states, including Florida, Indiana, Pennsylvania, and Texas, run separate state DNC registries with their own rules. If you call into those states, you need to pull those lists separately and run your own scrub. Relying only on BatchLeads' federal scrub in a state-registry state is a real compliance gap.

What happens if I call a number on the Do Not Call list through BatchLeads?

The liability is yours, not BatchLeads'. Under 47 U.S.C. § 227(c)(5), consumers can sue for $500 per violation, up to $1,500 if the violation was willful. Using BatchLeads is not a defense. It is a data tool; compliance responsibility sits with the entity making the calls. Not knowing the number was registered does not eliminate your exposure.

Can BatchLeads prevent me from calling cell phones without consent?

No. The DNC registry scrub does not touch TCPA wireless consent requirements. Calling or texting a cell phone using an ATDS or prerecorded voice without prior express consent violates 47 U.S.C. § 227(b)(1)(A), regardless of whether the number is on the DNC registry. BatchLeads does not verify consent status for cell numbers. You need a separate consent management process for wireless outreach.

How often should I refresh my DNC scrub when using BatchLeads?

FTC rules require telemarketers to download updated registry data no more than 31 days before making calls. Even if BatchLeads' scrub is current, treat each campaign as needing a fresh scrub within that 30-day window. If BatchLeads refreshes less often than that, supplement with a direct FTC registry download for your active area codes before each campaign runs.

Does BatchLeads include a litigator list scrub?

No. BatchLeads does not scrub against litigator lists, the private databases of phone numbers tied to known TCPA plaintiffs and plaintiff attorneys. For high-volume outbound, especially in litigation-heavy states like California and Florida, adding a third-party litigator scrub through a service like Contact Center Compliance is worth the nominal per-record cost.

How do I maintain an internal DNC list when using BatchLeads?

BatchLeads has a suppression or exclusion feature, but it is not built for regulatory internal DNC compliance. The safer practice is to keep your master internal DNC list in a spreadsheet or CRM as your system of record, then import it as a suppression file into BatchLeads before each campaign. FTC rules at 16 C.F.R. § 310.4(b) require you to honor internal DNC requests within 30 days and keep records for 5 years.

What is the cost of accessing the National Do Not Call Registry directly?

The FTC provides access for free for up to five area codes per year. Beyond that, the fee is roughly $79 per area code per year as of recent pricing, though the FTC can change it. You register at donotcall.gov to get access. This direct access lets you download registry data and run your own scrub against any list, including lists pulled from BatchLeads.

Can BatchLeads be used for SMS outreach and is that covered by its DNC scrub?

BatchLeads can build lists for SMS campaigns. The DNC scrub helps you avoid federally registered numbers, but SMS to cell phones carries extra TCPA requirements around prior express written consent that the scrub does not address. Texting a cell number without consent using a bulk platform may qualify as an ATDS violation under 47 U.S.C. § 227(b)(1)(A), independent of whether the number is on the DNC registry.

Does the DNC registry cover business phone numbers?

The federal National Do Not Call Registry covers personal landlines and cell phones but does not cover business-to-business calls. Some state registries do apply to certain business numbers. If you run B2B outreach, the federal DNC registry is largely not your issue, but TCPA wireless restrictions and state rules can still apply depending on the call type and the state.

How does BatchLeads compare to dedicated DNC compliance vendors?

BatchLeads is a real estate lead and skip-trace tool with DNC scrubbing as a secondary feature. Dedicated compliance vendors like Contact Center Compliance, Gryphon Networks, and DNC.com offer daily-refreshed federal and state registry scrubs, litigator list suppression, audit trails, and regulatory documentation. For teams with significant legal exposure or high call volume, dedicated compliance tools give you more defensible coverage than BatchLeads alone.

What number do consumers call to register on the Do Not Call list?

Consumers register by calling 1-888-382-1222 from the phone number they want to register, or online at donotcall.gov. Registration is free and permanent. Our page on the do not call list number covers this in detail for consumers who want to understand how their number shows up in registry scrubs.

Is there a way to check if a specific number is on the Do Not Call list before calling?

If you are registered with the FTC as a telemarketer and have area code access, you can check whether a number is in the registry download for that area code. There is no public individual-number lookup tool. The FTC's database access is provided for compliance use, not for real-time per-number checks in most implementations. BatchLeads automates this comparison during its list-building process.

Do real estate investors need to comply with the Do Not Call Registry?

Yes, if they make unsolicited outbound calls or texts to solicit a property purchase or business transaction, the FTC's Telemarketing Sales Rule and the TCPA apply. The exemption for personal calls does not extend to systematic prospecting campaigns. Real estate wholesalers making volume calls are acting as telemarketers under federal law and must comply with DNC registration and consent requirements.

Sources

  1. FCC and FTC 2024 inflation-adjusted civil penalty amounts (Federal Register annual adjustment): TCPA per-violation penalty up to $500, trebled to $1,500 for willful violations; FTC TSR civil penalty of $51,744 per violation as of the 2024 inflation adjustment
  2. Cornell LII, 47 U.S.C. § 227 Telephone Consumer Protection Act: TCPA prohibits ATDS calls to cell phones without consent; prohibits calls to DNC-registered numbers without established business relationship; private right of action for $500 to $1,500 per violation
  3. FTC, National Do Not Call Registry Data Book FY2023: The National DNC Registry contained over 244 million registered phone numbers as of 2023; 3.5 million complaints logged in fiscal year 2023
  4. National Association of Attorneys General, State DNC Registry overview: Twelve states maintain their own Do Not Call registries with requirements beyond the federal registry
  5. FTC, Telemarketing Sales Rule 16 C.F.R. § 310: TSR requires telemarketers to maintain internal DNC lists, honor requests within 30 days, and keep records for 5 years under 16 C.F.R. § 310.4(b)(1)(iii)
  6. U.S. Supreme Court, Facebook Inc. v. Duguid, 592 U.S. 395 (2021): Supreme Court held that an ATDS must use a random or sequential number generator to qualify under TCPA, narrowing the definition
  7. FTC, National Do Not Call Registry (business and telemarketer access): Telemarketers must download updated DNC registry data no more than 31 days before making calls; five area codes free annually, approximately $79 per additional area code per year
  8. FTC, National Do Not Call Registry (consumer complaint reporting): Consumers can register at donotcall.gov or by calling 1-888-382-1222; consumers can report DNC violations to the FTC at donotcall.gov

Disclaimer: LeadCompliant is a compliance review tool, not a law firm. We do not provide legal advice. Consult with a TCPA attorney for legal guidance on specific compliance questions. Compliance scores, audits, and risk assessments are informational only.

LeadCompliant Team

LeadCompliant provides expert guidance and tools to help you succeed. Our content is reviewed for accuracy and kept up to date.

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