TCPA compliance checker: outbound calling quiet hours, DNC, and consent

What TCPA compliance means for outbound calling

The TCPA compliance checker above runs three live validations against your inputs: a quiet-hour window calculator that converts your dialer time to the called-party local time and overlays state rules, a six-item DNC and consent suppression checklist that scores your exposure tier, and an FCC CG Docket 02-278 offshore disclosure decision tree that surfaces the exact disclosure script your sales and lead-gen calls need if any of your agents are based outside the United States.

The federal floor: 8:00 AM to 9:00 PM called-party local time

47 CFR 64.1200(c)(1) prohibits telephone solicitations before 8:00 AM or after 9:00 PM at the called party's location. The clock is the consumer's local time, not the agent's, not the dialer's, not the company HQ's. A dialer in Caribbean Eastern time placing a call at 8:30 AM to a California (Pacific) consumer is dialing at 5:30 AM Pacific, which is a TCPA violation regardless of the agent's local clock. Production dialers must geocode every record by area code or street address and gate dial decisions on the called-party time zone.

The FTC Telemarketing Sales Rule (16 CFR 310.4(c)) mirrors the same 8-to-9 window for B2C telemarketing. The two rules are functionally identical, but enforcement is split: FCC enforces against carriers and dialers, FTC enforces against marketers, and state attorneys general piggyback on both with state-specific damages.

State overlay rules table

Eleven states tighten the federal 8-to-9 window. The most common tightenings are a 9 AM start (Maine, Michigan, Minnesota, Texas weekdays), an 8 PM end (Maryland, Massachusetts, Nevada, Washington), and weekend-specific carve-outs (Connecticut Saturday + Sunday 9 AM start, Florida Sunday before 1 PM blackout, Wisconsin weekend 9 AM start, Texas Sunday noon start, Massachusetts no Sunday calls at all).

The other 39 states plus DC default to the federal 8 AM to 9 PM window. The FCC call-time rules deep dive walks through how dialers should encode these per-state overlays.

DNC suppression: four lists you must scrub

1. Federal DNC. The National Do Not Call Registry. Subscribers can register their numbers and a telemarketer must scrub the registry every 31 days for calls under the FTC TSR and 47 CFR 64.1200. Exceptions: established business relationship (EBR) within 18 months, written consent, charitable, political, or survey calls.
2. State DNC. Several states maintain their own DNC registries in addition to federal (notable examples: Indiana, Tennessee, Wyoming, and select others). Operators dialing nationwide must subscribe to and scrub against every active state list, not just federal.
3. Internal company DNC. Every prior opt-out, hang-up-equals-stop, and any consumer who has asked your company specifically not to call again. Required separately from federal under 47 CFR 64.1200(d). Internal DNC is the most-overlooked list in BPO programs; auditors check it first.
4. FCC Reassigned Numbers Database (RND). Live since November 2021. Catches numbers where the subscriber has changed since you captured consent. If you call a number after the original consenting party gave up the line and a new consumer took it, you are calling without consent. RND query gives a safe-harbor defense.

Best-practice (not required): scrub against litigator and serial-plaintiff lists. A handful of vendors maintain lists of known TCPA plaintiffs whose lawsuits drive most class actions. Scrubbing these out is a cheap exposure hedge.

Reassigned Numbers Database (FCC RND)

The RND launched November 2021 and resolved a decade of litigation ambiguity about reassigned-number calls. Before RND, callers who reached a number whose subscriber had changed faced strict-liability TCPA exposure even when they had captured valid consent from the original holder. RND gives callers a safe-harbor: query the RND for the date your consent was captured, get a yes/no on whether the number was reassigned, and if RND reports no reassignment between consent date and call date, you have a defense.

Operators integrate RND in two patterns. Batch scrub (monthly or weekly) is cheaper. Real-time query at dial-time is more expensive but lower latency on lead-list freshness; recommended for high-volume B2C programs where leads age fast.

Prior express written consent for autodialed and prerecorded calls

The TCPA distinguishes between two consent standards. For ordinary, manually-dialed informational calls, plain consent is sufficient. For autodialed or prerecorded calls to mobile phones placed for marketing purposes, the higher bar of prior express written consent applies under 47 USC 227(b)(1)(A). The written consent must clearly identify the seller, disclose that the call will be made using an automated dialing system or prerecorded voice, list the specific phone number being authorized, and not be a condition of purchase.

The 2023 FCC one-to-one consent rule, which took effect in 2024, tightened the standard further. Consent must now be specific to a single seller, ending the lead-aggregator practice of capturing consent for thirty marketing partners under a single checkbox. Operators using lead vendors must confirm each lead carries seller-specific consent, not blanket consent. The TCPA outbound voice 2026 breakdown walks through how lead-buyer programs should document this.

FCC CG Docket 02-278 offshore disclosure requirements

FCC Consumer and Governmental Affairs Bureau Docket 02-278 governs telemarketer location disclosure. The core rule: if a telemarketer uses agents located outside the United States to place calls to US consumers, the agent must disclose that the call is originating from outside the US. The standard script is some variant of: Some of our customer service agents may be located outside the United States.

The rule applies most clearly to consumer (B2C) sales and lead-generation calls. B2B and inbound customer service have softer obligations, though state telemarketing rules (notably California) may still require disclosure. Operators running nearshore or offshore programs should bake the disclosure into the opening script and document it in QA scoring. The FCC CG Docket 02-278 compliance checklist walks through the exact wording and where it must appear in the call flow.

Penalties and enforcement

TCPA statutory damages are $500 per call for negligent violations and up to $1,500 per call for willful or knowing violations. There is no cap on aggregate exposure. Class certification is routine in TCPA cases because the harm (an unwanted call) is identical across class members. A single class action covering 100,000 wrongly-dialed calls at $500 per call is $50 million in exposure.

FTC TSR violations carry civil penalties up to $50,120 per violation (2024 adjusted), plus state attorney general parallel actions. The FCC itself enforces via Notice of Apparent Liability (NAL) proceedings with consent decrees often in the seven to eight figures for repeat offenders.

The tech-enabled compliance approach

Compliance is not a binder of policies; it is dialer configuration plus consent ledger plus automated suppression. The CFG operational pattern stacks four controls:

• Dialer-side quiet-hour gating. Every record carries a called-party time zone (geocoded at lead capture). The dialer refuses to place a call outside the 8 AM to 9 PM local window plus any active state overlay. Manual override is logged and supervisor-approved only.
• Automated DNC scrubbing. Federal DNC scrubbed every 31 days. State DNC scrubbed every 31 days. Internal DNC updated within 30 days of consumer opt-out. RND queried in batch or at dial-time depending on program volume.
• Seller-specific consent ledger. Every lead carries a consent record tied to a single seller. Lead-vendor leads are rejected unless the consent record names your specific company.
• Offshore disclosure baked into opening. If any agent on the campaign is located outside the US, the disclosure is in the first 10 seconds of the call script and QA-scored every call.

The structural advantage of running outbound from a Caribbean nearshore fronter perimeter is timezone alignment. Caribbean ET is the same as US ET. Agents dialing US ET consumers in the morning are not battling the 11-to-13 hour shift inversion that drives offshore burnout and creates compliance lapses when night-shift agents drift outside the called-party window.

FAQ

Keep going

For deeper reading: TCPA compliance for call center outsourcing, FCC outbound calling regulations 2026, FCC call-time rules deep dive, TCPA outbound voice 2026, outsourced TCPA training for voice agents, and the FCC CG Docket 02-278 compliance checklist. For verticals where TCPA exposure is heaviest, see our debt collection outsourcing, solar pilot, and B2B SDR pilot. To talk to our compliance lead, head to contact.