Do Not Call (DNC) scrubbing is the step telemarketers take to cross-reference their call lists with the Federal Trade Commission’s (FTC) National Do Not Call Registry. This ensures they’re not calling folks who’ve decided they’d rather not get telemarketing calls and keeps them compliant with FTC and state laws.

Honoring the DNC list is crucial because slipping up can be costly. Calling someone on the list can carry a fine of up to $50,120 per call according to federal law, and states could add penalties of up to $25,000 for each violation. Additionally, individuals can sue violators for damages, which could be up to $500 for every call they shouldn’t have received.

Do Not Call List Fine Requirements

Companies must adhere to specific requirements to avoid fines related to the Do Not Call List. The fundamental requirement is that any company not exempt from DNC regulations must synchronize its calling lists with the National DNC Registry at least every 31 days.

This involves downloading an updated list of phone numbers from the registry and removing any that appear on it from their own calling lists. Failure to comply with this requirement can result in fines of up to $50,120 per incident.

Companies must also honor consumer requests not to be called, even if an established business relationship (EBR) exists. An EBR allows a company to call a consumer for up to 18 months after the consumer’s last transaction or payment, but this permission ends immediately if the consumer asks not to be called???.

Do Not Call State Regulations and Fines

In addition to federal regulations, several states have implemented their own DNC lists and regulations, which have different requirements and penalties. Currently, 11 states maintain their own Do Not Call lists: Colorado, Florida, Indiana, Louisiana, Massachusetts, Missouri, Oklahoma, Pennsylvania, Tennessee, Texas, and Wyoming.

So what does this mean exactly? Because of these additional state requirements, telemarketers must scrub calls against these state lists as well as the national list. The specific fines and enforcement actions can vary significantly from state to state, and these local regulations can be stricter and more actively enforced than federal ones.

This makes it crucial for companies to be aware of and comply with both federal and state DNC regulations when making telemarketing calls.

Here are the fines for each state with its own DNC list:

  • Florida: Up to $500 per violation or up to $1,500 each for willful violations
  • Colorado: $300 to $500 for the first offense and $500 to $1,000 for the second offense
  • Louisiana: Up to $1,500 per violation or up to $3,000 if the call recipient is 65 or older, and additionally, up to $10,000 if the violator isn’t properly registered with the LPSC Do Not Call General Order
  • Massachusetts: Up to $11,000 
  • Missouri: Up to $5,000 per violation
  • Oklahoma: $500 fine and/or one year in county jail for the first offense, and up to $10,000 and/or up to 10 years in prison
  • Pennsylvania: Up to $1,000, or up to $3,000 if the person contacted is 60 or older. 
  • Tennessee: Up to $2,000 per violation
  • Texas: Up to $1,000 for each violation
  • Wyoming: $500 for the first violation, $2,500 for the second, and $5,000 for the third and subsequent violations
  • Indiana: $10,000 for the first violation and $25,000 for each additional violation

How to Do a Manual DNC Scrub

If you want to roll up your sleeves and tackle DNC scrubbing manually, be aware that it requires serious attention to detail and careful data handling.

Here are the steps you’ll need to follow to do a manual DNC scrub:

  1. Learn the Rules: Take a look at the National DNC Registry’s policies so you know exactly what to expect.
  2. Register Your Company: If you need to, register with the DNC Registry to get your ID.
  3. Sort Out Your Area Codes: Jot down the area codes you’ll call.
  4. Download the List: Use your Subscription Account Number (SAN) to download the DNC lists for the area codes you’ll call.
  5. Check State-Specific Rules: Check if any states you are calling have their own DNC lists and registration requirements. Keep in mind that most states charge a fee to access their lists.
  6. Scrub Your List: Check the numbers you plan to call against the DNC lists and remove any on the list.
  7. Document Everything: Keep track of your scrubbing process in case you need to provide proof of compliance.

Remember that the DNC list is frequently updated, so you’ll want to continually update your list to ensure you’re staying compliant.

How to Do a Free DNC Scrub

You can do a free DNC scrub using EVS7’s complementary tool. This tool is perfect for small businesses that manage their DNC list downloads directly from the FTC. 

Although this tool is free, keep in mind that you still have to access the National DNC Registry. The FTC offers up to five area codes of DNC data for free. After five, each additional area code list is $78, up to a maximum annual fee of $21,402.

Here’s how the free DNC scrubbing tool works:

  1. Download the Tool: Visit the EVS7 website and download the free Do Not Call Scrubber.
  2. Confirm SAN: If you haven’t already, sign up for a Subscription Account Number from the National DNC Registry.
  3. Prepare Your Lists: Collect your calling list and the downloaded DNC list from the registry.
  4. Upload Lists: Open the DNC Scrubber tool and upload both your calling list and the DNC list.
  5. Scrub: Run the tool to scrub the DNC numbers from your calling list.
  6. Result: The tool will provide a new calling list that excludes any DNC numbers, ensuring your list is compliant.

Faster Ways for DNC Scrubbing

Below are a few options for automated DNC scrubbing that help ensure compliance with federal and state regulations.

  • Do Not Call Scrub Lite: You can scrub up to 25 records per month for free or purchase a subscription plan to scrub more records per month.
  • Scrub DNC: This tool allows scrubbing against DNC lists, with three product tiers ranging from $59.99 to $99.99 that determine how many lists you can do.
  • DNC Scrub: You can submit small batches of phone numbers for quick scrubbing, and it can also exclude EBR lists from scrubs and give reminders when EBRs are about to expire.
  • TheDNCProject.org: This system enables instant scrubbing of numbers, provides real-time progress updates, and can process up to 2 million numbers in about five minutes?.