Call Center Compliance Guide

Key Regulations

TCPA (Telephone Consumer Protection Act)

• Requires prior express consent for autodialed/prerecorded calls
• Consent is tied to the person, not the number
• Calling reassigned numbers can violate TCPA
• Penalties: $500-$1,500 per violation

FDCPA (Fair Debt Collection Practices Act)

• Prohibits disclosing debt to third parties
• Calling wrong person about debt violates FDCPA
• Right-party contact is essential

TSR (Telemarketing Sales Rule)

• Requires DNC list compliance
• Calling time restrictions (8am-9pm local)
• Caller ID requirements

State Laws

• Many states have stricter requirements
• California, Florida, and others have additional consent rules
• Some states restrict certain line types

Reassigned Number Liability

When phone numbers are disconnected, carriers reassign them to new customers. Your consent from the original owner doesn't transfer to the new owner.

• ~35 million numbers reassigned annually
• Each call to reassigned number is potential violation
• Class actions target high-volume callers

How LRN Activation Date Helps

LRN Activation Date shows when a number was last ported or activated. Compare against your last contact date:

# Detect potentially reassigned numbers
last_consent_date = contact.consent_date
activation_date = lookup_result['lrn']['activation_date']

if activation_date > last_consent_date:
    # Number may have been reassigned after consent was given
    # Do not call without re-verification
    flag_for_compliance_review(contact)

Reasonable Procedures Defense

The FCC provides a "safe harbor" for callers who implement reasonable procedures to identify reassigned numbers. Phone validation supports this defense:

1. Validate numbers before calling
2. Check activation dates against consent dates
3. Stop calling when you learn a number is wrong
4. Document your procedures

Compliance Workflow

Before Calling

1. Scrub against DNC lists (federal and state)
2. Verify consent is on file
3. Check LRN Activation Date vs. consent date
4. Flag numbers activated after consent for review

During Call

1. Verify identity before discussing sensitive information
2. Document wrong-party contacts immediately
3. Update records when told number has changed

After Wrong-Party Contact

1. Stop calling that number immediately
2. Flag record as potentially reassigned
3. Do not attempt further contact
4. Document the interaction

Line Type Compliance Considerations

Documentation Requirements

• Consent records — When and how consent was obtained
• Validation records — When numbers were validated
• Call attempts — Time, outcome, agent notes
• Wrong-party contacts — When identified, action taken
• DNC scrub records — Proof of compliance

Best Practices

1. Validate regularly — Fresh data reduces risk
2. Use LRN Activation Date — Detect reassigned numbers
3. Document everything — Create audit trail
4. Train agents — Proper verification procedures
5. Stop when told — Honor wrong-party notifications immediately
6. Consult legal counsel — Regulations vary by use case