If you make outbound calls in the United States, scrubbing your list is not a one-time task. Federal rules require you to check your calling list against the National Do Not Call Registry at least once every 31 days, and drop any number that has registered since your last check. Miss that window and every call to a newly registered number is a potential violation.
The Telemarketing Sales Rule requires sellers and telemarketers to refresh their lists against the registry no less than every 31 days. The registry is not static. Consumers add their numbers every day, and once a number is on the list it stays there. That means a list you scrubbed clean five weeks ago already has registered numbers in it today.
The 31-day figure is a ceiling, not a target. It is the longest you can go between scrubs, not the recommended cadence. Most disciplined callers scrub before every campaign rather than counting days, because a campaign that launches on day 30 of an old scrub is running on data that is nearly a month stale.
Calling a number that registered after your last scrub is treated the same as calling any other registered number. A Telemarketing Sales Rule violation can cost up to $53,088 per call. On top of that, consumers can sue directly under the TCPA for $500 to $1,500 per call, and those claims are often filed as class actions. The registry does not care that your list was clean last month. It only matters whether the number was registered at the moment you dialed.
The simplest approach is to scrub immediately before each campaign, not on a calendar. That way your list reflects the registry as it stands the day you call, and you never have to track how many days have passed since the last refresh.
Because our copy of the registry updates daily, a scrub run the morning of a campaign gives you the current list. Upload your file, remove the flagged numbers, and dial a list that is clean as of that day. For teams that call continuously, the API lets you scrub in real time inside your dialer, so the 31-day question never comes up at all.
Keep records, too. We store timestamped proof of every scrub, which is what you want on hand if a complaint ever leads to questions about when you last checked the list.
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