How do I screen a property-owner call list against Do Not Call and internal suppression lists?

Screening means five passes over the file before dialing, and what follows explains public rules and is not legal advice. Two passes check lists: the National Do Not Call Registry, reached through your own Subscription Account Number, and the entity-specific do-not-call list recording anyone who has told you to stop.[3][1] A third pass asks whether you hold consent for the channel you plan to use, while the last two are paid scrubs against litigator files and against the FCC's record of reassigned numbers.[4][10][12]

The calling window governs whatever survives all five passes, and the Telemarketing Sales Rule sets it at 8 a.m. to 9 p.m. local.[1] Calling a person's home outside that window without prior consent is one of the acts the FTC defines as abusive.[1] Working a cold public-records list also gives you no established business relationship to fall back on, which places every row inside the registry rule from the first dial.[1]

The TCPA lets a called party recover $500 for each violation, and a court may treble that award for a willful or knowing violation.[2] The FTC's guide puts civil penalties for a Telemarketing Sales Rule violation at up to $53,088 each, and calling a consumer who already asked you to stop is a separate violation carrying that same exposure.[1]

Sequence decides more than software, because the registry scrub expires on a 31-day clock.[3] The entity-specific list has to be written to the moment a request arrives, and the consent question sits ahead of both because it governs whether an autodialed campaign was available at all.[4] Registry access is free for up to five area codes while litigator screening runs on a separate commercial subscription, so running the free passes first shrinks the file you pay to screen.[3][12] A number can change hands between the data append and the dial, which is why the reassigned-number query runs last on rows whose consent predates the file.[10]

Access runs through a Subscription Account Number issued to you as the seller.[3] The FTC allows you to direct a telemarketer to complete the online subscription on your behalf, although you must still hold your own subscription and SAN separate from the telemarketer's.[3]

Data for up to five area codes costs nothing.[3] Beginning October 1, 2025 the annual fee is $82 per area code of data beyond those five, up to a maximum annual fee of $22,626.[3] Anyone required to use the registry has to synchronize calling lists with an updated version at least every 31 days.[3]

That 31-day number reappears as a condition of the FTC's Do Not Call safe harbor, which protects you from penalties for an erroneous call.[1] Protection depends on written procedures to honor do-not-call requests, trained personnel, a maintained and recorded entity-specific list, and a documented process relying on a registry version downloaded no more than 31 days before the call.[1]

PropertyRadar requires you to register on the National DNC Registry website and obtain a Subscriber Account Number before it will show DNC data.[11] Scrubbing numbers against the registry costs nothing once a SAN is entered, and the app automatically scrubs past saved lists when you submit one.[11] Coverage stops at one number per person, because the DNC criteria apply only to the first phone number in the Primary Contact's record and exports carry only that first number, so any other active number on the same contact leaves the app unflagged.[11]

Any owner who has told you to stop belongs on a list you maintain yourself.[1] Calling a consumer who has asked not to be called again violates the TSR on its own, and the FTC puts that duty on you as the seller whether you keep the list through a telemarketing service you hire or through your own efforts.[1]

The FCC's implementing rule requires a written policy for maintaining a do-not-call list, available upon demand.[4] You also have to inform and train every person engaged in any aspect of telemarketing in the existence and use of that list.[4] A request has to be recorded and the subscriber's name and number placed on the list at the time the request is made, honored within a reasonable time that may not exceed ten business days from receipt, and honored for 5 years.[4]

A do-not-call request applies to the particular entity making the call and does not extend to affiliated entities unless the consumer would reasonably expect them included.[4] Paragraph (e) of that rule applies the calling-window and do-not-call provisions to telemarketing calls or text messages sent to wireless numbers, which covers most of a skip-traced owner file.[4]

Consent under the TCPA attaches to a specific number and a specific technology.[4] The FCC defines prior express written consent as an agreement in writing bearing the signature of the person called, clearly authorizing the seller to deliver telemarketing messages using an automatic telephone dialing system or an artificial or prerecorded voice, naming the telephone number to which they may be delivered.[4]

A called party may revoke prior express consent by any reasonable method.[4] Replying with stop, quit, end, revoke, opt out, cancel, or unsubscribe to an incoming text is a reasonable means per se, after which you may not send additional robocalls or robotexts.[4]

The Eleventh Circuit vacated Part III.D of the FCC's 2023 Order on January 24, 2025.[5] The court held that the Commission exceeded its statutory authority because the new consent restrictions conflicted with the ordinary statutory meaning of prior express consent, which is why the stricter one-to-one consent rule never took effect.[5] What survives is the statute itself, which still requires the called party's prior express consent for a robocall.[2]

An established business relationship permits live telemarketing calls from a sales agent and never automated calls or robocalls.[1] It disappears once the consumer asks to be placed on your entity-specific list, and its longer form runs 18 months from the consumer's last payment, transaction, or shipment, while the inquiry form runs only three months.[1]

The FCC bars calls to any residential telephone subscriber before 8 a.m. or after 9 p.m. local time at the called party's location.[4] The FTC lists calls outside that window among the acts defined as abusive under the TSR, so the federal outer window runs 8 a.m. to 9 p.m. wherever the phone rings.[1]

The TSR does not preempt state law, which the FTC states outright in its compliance guide.[1] Florida bars a commercial telephone solicitation phone call before 8 a.m. or after 8 p.m. local time in the called person's time zone, including calls made through automated dialing or recorded messages.[6] Fla. Stat. § 501.616(6) also caps outreach at three commercial solicitation calls from any number to a person over a 24-hour period on the same subject matter, and the section requires a commercial telephone seller to be licensed.[6]

Florida's autodialer rule sits in a different statute, since § 501.059(8)(a) bars an unsolicited telephonic sales call involving an automated system for the selection and dialing of telephone numbers.[7] That bar covers a recorded message played when a connection is completed, absent the prior express written consent of the called party, and subsection (10) lets an aggrieved called party recover actual damages or $500, whichever is greater.[7] A court may increase that award up to three times for a willful or knowing violation, and a text solicitation under that section carries a pre-suit step because the called party must first reply STOP to the number before commencing an action for damages.[7]

Oklahoma's Telephone Solicitation Act of 2022 reads similarly on hours and frequency.[8] A legal-library transcription of 15 O.S. § 775C.4 quotes a bar on solicitation calls before 8 a.m. or after 8 p.m. in the called person's time zone, with a limit of three such calls from any number over a twenty-four-hour period on the same subject.[8] That transcription is a secondary source, so read the section on the state's own statute portal before you build a calling schedule on it.

No federal registry lists serial TCPA plaintiffs, so litigator screening runs on commercial files you subscribe to separately.[12] PropertyRadar's account settings carry a Telemarketing Settings section covering national Do Not Call access and a Blacklist Alliance integration.[12] Integrating Blacklist Alliance lets you scrub phone numbers against known State Do Not Call lists, known litigators, and other high-risk contacts, and a separate Blacklist Alliance subscription is required.[12]

Whatever the screens return shows up as a status on the contact record instead of removing the row.[13] A green checkmark on a PropertyRadar contact means the number is active and safe to call or text, while a yellow triangle covers a different status such as opted out, wrong person, disconnected, Do Not Call where you have accessed DNC data, or blacklisted where you have connected a Blacklist Alliance account.[13]

The FCC counted approximately 35 million numbers disconnected and made available for reassignment each year when it created the Reassigned Numbers Database.[9] Service providers are required to submit data on permanently disconnected numbers monthly, and its operator describes a voluntary caller query as a safeguard against the statutory damages that accompany inadvertently calling or texting a reassigned number.[10]

The TSR requires most sellers and telemarketers to keep certain records for two years from the date the record is produced.[1] A do-not-call request runs on a longer clock at 5 years, and the safe harbor separately requires records documenting the process used to prevent calls to numbers on either list, so three retention periods run at once on a single campaign.[1][4]

PropertyRadar's user agreement runs longer than either regulator, requiring TCPA consent records for each call recipient.[14] Those records cover the name, phone number, the date and time consent was provided, the IP address and referral URL where it was submitted, and the contents of the registration form, all maintained for a minimum of six years.[14]

Consent goes first on any campaign that uses a dialer, a prerecorded voice, or SMS.[4] A row without prior express written consent is unavailable through those channels no matter how clean the registry scrub looks, and a public-records list appended with purchased numbers carries no signed agreement.[4]

The registry scrub follows, dated inside 31 days of the call and run under your own SAN.[3] A scrub run on somebody else's account fails the safe harbor condition that you hold your own subscription, which removes the protection you were paying for.[1][3]

Litigator and state-file screening runs on the survivors through a separate subscription, and the reassigned-number query runs on rows whose consent or contact data predates the file.[10][12] The entity-specific suppression list is checked last and stays open during the campaign, because it is the only file you write to while dialing, and a request that lands mid-campaign has ten business days to reach it.[4]

No product screens a list into compliance, which is why every platform in this workflow writes the duty back to you in its own terms.[14] PropertyRadar's user agreement states that phone numbers it provides may be subject to state and federal do not call regulations and that compliance is solely the user's responsibility.[14]

A scrub proves that a process ran on a date against a version of a file, and the safe harbor is built around that evidence more than around a clean result.[1] A registry version downloaded 32 days before a call sits outside the safe harbor, so a wrong number dialed from that list carries no erroneous-call protection.[1]

The national registry is also not a state registry, and it does not cover known litigators, so a clean national scrub leaves both exposures open.[12] The entity-specific list is separate again, because it records people who spoke to you rather than people who filed with the FTC.[1]