# The Dial-List Clearance Standard: Dial, Hand-Dial Only, Voice-Only, Suppress

*Grade any sourced number to one of four verdicts exactly as a colleague would, and produce a per-load record showing which check cleared it and when it expires.*

- Canonical URL: https://www.refolk.ai/guides/dial-list-clearance-standard
- Pillar: Process, data, and compliance
- Format: Standard
- Published: 2026-11-03
- Last reviewed: 2026-11-03
- Reading time: 22 min
- Keywords: can you cold call cell phones b2b, how often to scrub call list against do not call registry, reassigned numbers database before calling, do not call rules for text messages b2b, is recruiter calling a candidate a telephone solicitation, state do not call list scrub requirements

## Key takeaways

- Under both FTC and FCC rules, the national registry download used to block calls can be no more than 31 days old, so every cleared number in this standard expires 31 days after its scrub, or sooner if a verified state rule is shorter.
- The TSR's B2B exemption covers company switchboards and direct office lines but never clears a sourced mobile on its own, because the FCC applies TCPA residential protection to wireless numbers and marketing texts.
- A Reassigned Numbers Database 'No' supports a safe harbor only when the caller submitted a real consent date, so querying a cold sourced number produces evidence but no defense.
- The FCC treats a recruiter's call as outside 'telephone solicitation' only if nothing is sold during or after the call, so one staffing cross-sell turns a recruiting campaign into a sales campaign.
- In Refolk's index of US professional profiles, recruiters outnumber SDRs about 4.3 to 1, yet just 1 profile at a Staffing and Recruiting company lists TCPA as a skill, against 237 in Financial Services.
- Store both the area-code state and the claimed residence state for every number and apply the stricter one, because Florida, Oklahoma, and Maryland each cap solicitation calls at 3 per 24 hours.

This standard grades every sourced phone number before it goes into a dialer or texting tool. Each number gets one of four verdicts: Dial, Hand-Dial Only, Voice-Only, or Suppress. It is written for recruiting operations, revenue operations, and anyone who has to answer for how a list was gathered. It covers the six criteria, the order you apply them in, the clearance procedure, and the evidence record. That record shows which check cleared each number and when the clearance expires.

## What the four verdicts mean

Each number gets exactly one verdict. The verdict names the widest contact method the evidence supports, from Dial (every method) down to Suppress (no phone or text contact at all).

| Verdict | Live-agent dialer | Hand dial | Text |
|---|---|---|---|
| Dial | Yes | Yes | Yes |
| Voice-Only | Yes | Yes | No |
| Hand-Dial Only | No | Yes | No |
| Suppress | No | No | No |

The table depends on three definitions:

- **Dialer**: any tool that places calls without a person keying in each number, including power and predictive modes. My sources do not settle the legal definition of an autodialer, so the standard doesn't rely on it. It treats every tool that dials in volume as automated. If your counsel draws the line somewhere else, record that as a written amendment. Don't leave it as a call someone makes at their desk.
- **Hand dial**: a person dials one number from a manual interface and speaks to whoever answers.
- **Text**: any SMS or MMS sent from any tool, including a rep's own phone.

Two rules apply on top of every verdict:

1. No verdict permits a prerecorded or artificial-voice message unless there is a consent record.
2. Every verdict carries an expiry date. Once that date passes, the number is Suppress until it is cleared again.

## Which rules apply to a sourced phone number?

Three layers of law can each block a call: the FTC's Telemarketing Sales Rule (TSR), the FCC's TCPA rules in 47 CFR 64.1200, and state mini-TCPA laws. Your internal do-not-call list sits beneath all three. Saying "it's B2B" only gets you past the first layer.

#### The layers a sourced number must clear

1. **State mini-TCPA laws** - Hours, 3-per-24-hours caps, text coverage, disputed B2B carve-outs; the stricter of two states governs
2. **TCPA rules in 47 CFR 64.1200** - Residential subscribers, extended to wireless numbers and marketing texts; consent for prerecorded calls to cells
3. **Telemarketing Sales Rule** - Most B2B calls exempt from DNC under 310.6(b)(7), but not from the ban on misrepresentation
4. **Internal do-not-call list** - Every request honored for five years, for every purpose and channel

*A number cleared at the TSR layer can still fail at the TCPA, state, or internal layer, and any single layer can veto the call.*

### The TSR layer: where "it's B2B" holds

The TSR exempts most business-to-business calls under §310.6(b)(7). The FTC later narrowed the exemption, which now prohibits material misrepresentations and false or misleading statements in B2B telemarketing calls. Even so, the DNC requirements have not been extended to B2B calls, and B2B sellers do not have to follow the TSR's recordkeeping rules. A company switchboard or an office direct line fits this exemption cleanly.

### The TCPA layer: where it stops holding

The TCPA's registry protection covers "residential telephone subscribers". The FCC applies it to wireless numbers and to marketing texts under §64.1200(e). A sourced mobile doesn't fit neatly into either rule, because many people use the same phone for personal and business calls. I found no source that settles whether courts treat a mobile used for business as residential.

So can you cold call cell phones B2B? The TSR exemption never clears a mobile by itself. This standard treats every mobile as residential, which stays safe however that open question gets resolved.

### Texts are calls

Courts disagree on whether a text message counts as a call:

- The Seventh Circuit, in Steidinger v. Blackstone, held that texts are not "telephone calls" under the DNC private right of action in Section 227(c)(5). It was the first federal appellate court to do so.
- The Ninth Circuit, in Howard, held that a text is a "call". It was interpreting Section 227(b), a different provision.
- District courts are split as well, including within Florida. On a single day, one district court in Illinois said texts are not calls and another in Oregon said they are.

> **Note:** What Steidinger did not change
>
> It narrowed who can sue in one circuit. It did not touch FCC enforcement, the 227(c) obligation itself, or state telemarketing laws, some of which expressly apply DNC rules to texts in Seventh Circuit states.

On do not call rules for text messages in B2B work, the standard is simple: a text gets the same DNC verdict as a voice call. One law firm notes that it is often impossible to know where all of a business's contacts are located. That alone is reason not to build a texting program on one circuit's ruling.

## The six criteria, what each proves, and how each lies

Each criterion is a field in the evidence record. Each one proves one narrow thing as of one date. You stop a clean-looking row from being dialed by knowing how each field can mislead you.

### 1. Line type

- **Proves:** what the carrier lookup reported (mobile, landline, or VoIP) and, for a landline, whether it resolves to a company switchboard or a personal line.
- **Lies when:** a profile with a work title lists a number that is really a personal cell. The title suggests business, but the line is residential. Go with the line.
- **Rule:** VoIP that does not resolve to a company switchboard is graded as mobile. Store the lookup date next to the result.

### 2. Registry status

- **Proves:** the number was absent from the national registry, the applicable state lists, and your internal list, each as of that list's date.
- **Lies when:** the download is stale, or the number's area code isn't in your national registry subscription. Registry access is priced per area code, so check that every area code in the load is covered. A number you couldn't check is not a clean number.
- **Rule:** record the result and list date separately for the national list, each state list, and the internal list.

### 3. Scrub age

- **Proves:** the clearance is still current.
- **Lies when:** a load imported on day 1 sits in a sequence and gets dialed on day 35.

| Check | Limit | Rule |
|---|---|---|
| National registry scrub age | 31 days | 64.1200(c)(2)(i)(D) |
| Internal DNC honor | 10 business days | 64.1200(d)(3) |
| Internal DNC retention | 5 years | 64.1200(d)(6) |
| Consent revocation honor | 10 business days | 64.1200(a)(10) |
| Opt-out confirmation text | within 5 minutes | 64.1200(a)(12) |
| RND date floor | Jan 27, 2021 | DA 21-1649 |

How often should you scrub a call list against the Do Not Call Registry? The FTC and the FCC both require the list used to block calls to be no more than 31 days old (16 CFR 310.4(b)(3)(iv) and 47 CFR 64.1200(c)(2)(i)(D)). For state lists, the interval depends on the state. The only state figure I found is one vendor's claim that Oklahoma requires a 30-day scrub, and I have not checked it against the statute. I could not find a primary-source table of state intervals.

- **Rule:** expiry is the national download date plus 31 days, unless either state field names a state with a shorter interval you have verified. If either field says Oklahoma, use 30 days until someone on your team has read the statute.

Sources also disagree about when to scrub. One vendor says to scrub before every dial, not just at import. Most describe a 31-day cycle. This standard runs registries on the cycle and checks the internal list at dial time, because opt-outs arrive every day. The 10-business-day window is the maximum you're allowed, not a target.

### 4. State

- **Proves:** which state laws could apply.
- **Lies when:** the area code is treated as the residence. A Florida resident with a 312 number gets Illinois treatment, and Florida's call cap is missed.
- **Rule:** record both the area-code state and the claimed residence state, and apply the stricter of the two on every dimension. If the claimed residence is unknown, write "unknown" and apply the strictest profile in the table below.

| State | Hours | Cap/24h | Texts | B2B |
|---|---|---|---|---|
| FL | 8am-8pm | 3 | yes | disputed |
| OK | 8am-8pm (one source: 9am start) | 3 | yes | covered unless narrow exemption |
| MD | 8am-8pm (some: 9am start) | 3 | yes | hours and cap apply |
| WA | 8pm cutoff | unverified | unverified | disputed |
| TX | unverified | unverified | yes | unverified |

The disagreements between sources are left in the cells on purpose. Vendor pages contradict each other on state DNC scrub requirements and B2B carve-outs because they are reading different subsections. Florida's hours and cap sit in the Florida Telemarketing Act (§501.616), which is separate from the FTSA. Maryland's B2B carve-out covers only the consent rule, so its hours and three-call cap still apply to B2B calls.

The house rules for state law:

- In any state in the table, B2B calls follow that state's hours and caps.
- Where sources disagree on hours, use the narrower window: 9am to 8pm for Oklahoma and Maryland.
- Apply state hours and caps to every purpose, recruiting included, because my sources do not set out each state's definition of solicitation.
- Everywhere else, use the federal window of 8am to 9pm in the recipient's local time.
- Texas SB 140 brought sales texts within the state's telemarketing rules. Registration requires a $10,000 security bond, though Secretary of State guidance exempts consent-based texters. In Texas, each call or text is a separate violation.

### 5. Call purpose

- **Proves:** which exemptions you can even claim.
- **The recruiting position:** the FCC's Bureau restated that "a recruiter's call to discuss potential employment or service in the military with a consumer is not a 'telephone solicitation' to the extent the called party will not be asked during or after the call to purchase, rent or invest in property, goods or services."
- **The case law:** Rockwell v. Medicus dismissed a DNC claim over recruiting calls. The court noted, though, that it lacked allegations about the workings of Medicus's business model and the role its professional services play.
- **Lies when:** a recruiter mentions the firm's services to a hiring manager. The carve-out holds only if nothing is sold during or after the call, so a single cross-sell makes the whole campaign a solicitation.
- **Rule:** set the purpose once per campaign, in writing, before the load. Log staffing business development as sales, because pitching a staffing service to a client company is selling a service.

So is a recruiter calling a candidate making a telephone solicitation? Under the FCC's position, no, as long as nothing is sold. That gets the call past the registry but not past the dialer rules. In Loyhayem, the court held that prerecorded job recruitment calls to cell phones require express consent under the TCPA.

### 6. Dial method and consent

- **Proves:** whether the number can go into a volume tool.
- **Lies when:** an RND "No" sits on a row that has no consent date. It looks like a clearance, but it isn't one.

The FCC Reassigned Numbers Database (RND) takes a number plus the date prior express consent was obtained. It reports whether the number has been permanently disconnected since that date. The three possible answers mean:

- **Yes:** no safe harbor.
- **No:** you may be eligible for the safe harbor.
- **No data:** no safe harbor. This comes back when the queried date is before January 27, 2021, the date all providers had to start keeping disconnect records.

Carriers report to the database monthly, so query close to the dial date. The safe harbor does not protect a caller who never had consent, skipped the query, used the wrong date, or dialed after getting Yes or No data. If you're wondering whether to check the reassigned numbers database before calling a sourced number, the answer is only when a real consent date exists.

#### Consent and line type set the ceiling

Horizontal axis runs from Company switchboard or office line to Mobile, personal landline, or unresolved VoIP. Vertical axis runs from No consent record to Consent date on file and RND No.

| Quadrant | What it means |
| --- | --- |
| Consented business line | Voice-Only; texting a switchboard is moot |
| Consented mobile | Dial if every text check passes, otherwise Voice-Only |
| Cold business line | Voice-Only under the TSR exemption, with the stricter state's hours and caps |
| Cold mobile | Hand-Dial Only, or Suppress on a registry hit for sales |

*Without a consent record, a mobile never rises above Hand-Dial Only, while a business switchboard can reach Voice-Only on the TSR exemption.*

## Who is dialing, and where the TCPA knowledge sits

In Refolk's index of US professional profiles, the people who dial the most are the least likely to list TCPA expertise. Recruiters outnumber SDRs about 4.3 to 1. TCPA appears as a skill on 237 Financial Services profiles and on 1 Staffing and Recruiting profile.

| Segment | Profiles |
|---|---|
| Title "Recruiter" | 94,624 |
| Title "Sales Development Representative" | 22,057 |
| TCPA skill, Financial Services | 237 |
| TCPA skill, Staffing and Recruiting | 1 |

**237 to 1 - TCPA-skilled profiles in Financial Services versus Staffing and Recruiting, US**

From Refolk's index; recruiters, the largest dialing population, sit almost entirely on the side with no listed TCPA expertise.

Read this with its limits in mind. A listed skill is not the same as knowledge, and plenty of capable people never list one. Still, the gap is too wide to blame on how people fill in profiles. The design follows from it: the verdict rules below have to work for a recruiting coordinator who has never read 64.1200. That's why every ambiguous case fails closed instead of asking the grader to judge.

If you'd rather hire the expertise than build it, it is concentrated in banking. In a 25-profile sample of TCPA-skilled Financial Services profiles, the top employers were Wells Fargo (6), Bank of America (3), and JPMorganChase (3). [Refolk](/) lets you describe that person in plain English rather than guessing which title keywords they used.

I ran this search: `Chief compliance officers at US banks with TCPA experience` - [see the full result list](https://www.refolk.ai/s/1chnyykcza).

*Returns matching compliance leaders with the public profile evidence behind each match, so you can see who has actually worked under the TCPA.*

## Verdict rules, in the order they are applied

Apply the nine rules from top to bottom and stop at the first one that fires. The order is the standard itself. Two graders agree because they ask the same questions in the same sequence.

1. **A required field is blank** (line type, lookup date, either state field, campaign purpose, or any scrub date): Suppress.
2. **The internal DNC list matches**: Suppress.
3. **The clearance has expired** at dial time: Suppress until the number is re-scrubbed.
4. **A consent date is on file and the RND came back Yes or No data, or was never queried**: Suppress.
5. **A national or applicable state registry hit, the purpose is sales or staffing BD, and the line is not a company switchboard**: Suppress.
6. **The line is a mobile, personal landline, or unresolved VoIP with no consent date**: Hand-Dial Only.
7. **The line is a company switchboard or office line**: Voice-Only.
8. **A consented mobile fails any text check**: Voice-Only. A text check fails when the consent record does not cover texts, when the texting tool can't send the opt-out confirmation within 5 minutes, or when either state field is Texas and you are relying on a registration you do not hold.
9. **Otherwise**: Dial.

> **Rule:** Fail closed, always
>
> A blank field, an unknown state, or an unqueried RND is a Suppress, never a judgment call made at the desk. If rule 5 is too strict for a consent-based sales program, have counsel write the exception into the standard before the load, not during it.

Three worked cases show that the order gives one answer each time:

- **Recruiting, mobile, on the national registry, no consent, area code 312, claimed residence Florida.** Rules 1 to 5 pass, because rule 5 applies only to sales. Rule 6 fires: Hand-Dial Only. Florida's 8am to 8pm window and 3-per-24-hours cap govern.
- **Sales, company switchboard, on the national registry, Maryland.** Rule 5 excludes switchboards, so rule 7 fires: Voice-Only. The window is 9am to 8pm with 3 calls per 24 hours.
- **Sales, mobile, consent dated after the RND floor, RND No, not on any registry, Texas, opt-out confirmation configured.** Rules 1 to 8 pass and rule 9 fires: Dial.

## How to clear a load, step by step

The procedure runs once per load, in this order, and its output is the signed evidence record. Most steps take minutes per load. Recording the campaign purpose takes about an hour per campaign.

#### Dial-list clearance procedure

1. **Classify each number by line type** - Run a carrier lookup and record mobile, landline, or VoIP, plus whether a landline resolves to a company switchboard. Done when every row has a line type and lookup date.
2. **Lock the call purpose per campaign** - The campaign owner records one purpose (sales, recruiting, or staffing business development, logged as sales). Done when a signed purpose declaration exists before grading.
3. **Record two state fields per row** - Data ops records the area-code state and the claimed residence state, writing unknown where needed. Done when every row has both fields.
4. **Scrub against national and state registries** - Use a national download no more than 31 days old covering every area code, plus applicable state lists. Done when each row carries a scrub date and an expiry date.
5. **Scrub against the internal DNC list** - Match every row against five years of internal requests across all channels. Done when zero matches remain in the dialable set.
6. **Query the RND for consented numbers only** - For rows with a consent date, query with that date and log Yes, No, or No data with the query date. Done when every consented row has a result.
7. **Assign dial method and verdict** - The ops lead applies the nine rules in order and records the verdict and the rule number that fired. Done when the evidence record is signed off.
8. **Enforce windows, caps, and expiry at dial time** - Configure the dialer and texting tool for the stricter state's hours, caps, row expiry, and a dial-time internal DNC check. Done when a test row past expiry is refused.

## The per-load evidence record

The evidence record has one header per load and one row per number, and you keep it for five years. It is your defense if a complaint arrives, because it shows which check cleared the number and when.

No primary source I found lists the fields a scrub record has to contain beyond the TSR's own list. The fields below are therefore house policy, not a legal minimum. The TSR requires five years of key records, including call details and consent records (§310.5). Section 64.1200(d) requires a written do-not-call policy, staff trained on it, recorded requests, and each request honored for five years. B2B sellers are exempt from the TSR's recordkeeping rules, but keep the record anyway. "We didn't have to" is a weak answer when a mobile turns out to be residential.

**Per-load evidence record (CSV header and load header)**

```
# LOAD HEADER
load_id, source_description, imported_on, national_dnc_download_date, area_codes_in_subscription_confirmed (Y/N), state_lists_checked, graded_by, signed_off_by, signed_off_on

# ROW FIELDS
load_id, row_id, number_e164, line_type, switchboard (Y/N), line_type_lookup_date, area_code_state, claimed_residence_state, residence_source, governing_profile, campaign_id, purpose, national_dnc_result, state_dnc_result, internal_dnc_result, internal_dnc_checked_at, consent_date, consent_record_ref, consent_covers_text (Y/N), rnd_result, rnd_query_date, verdict, verdict_rule_number, scrub_date, expires_on
```

*One row per number; keep field names stable so the dialer can read verdict and expires_on directly.*

**Campaign purpose declaration**

```
Campaign ID:
Purpose (one only): Sales / Recruiting / Staffing business development (graded as Sales)
Will the called party be asked, during or after the call, to buy, rent, or invest in anything? Yes / No
If No: script and follow-up sequence reviewed for any mention of the firm's services: Yes / No
Channels: Hand dial / Live-agent dialer / Text
Prerecorded or artificial voice used: No (requires consent record if Yes)
Owner name and date:
Reviewed by ops lead, name and date:
```

*Signed by the campaign owner before any row is graded; one per campaign, never per row.*

## How clearance goes wrong

Most clearance failures come from a field that looks like it answers a question it doesn't actually answer. Each failure mode below gives the false reading and the check that catches it.

1. **"It's B2B" applied to a sourced mobile.** The false positive is a profile with a work title whose number is a personal cell. Check: carrier line type plus registry result. Any registered mobile is residential for sales purposes.
2. **Area code used as the state.** The false negative is a Florida resident on a 312 number, graded under Illinois rules. Check: both state fields are stored, and the stricter one governs.
3. **An RND "No" read as clearance for a cold number.** The safe harbor needs a consent date, so a sourced number with no consent gets none. Check: the RND result counts only when the consent date field is non-null and on or after the database floor.
4. **A stale scrub.** A load imported on day 1 gets dialed on day 35. Check: every row has an expiry date, and the dialer refuses expired rows instead of relying on a reminder.
5. **A recruiting campaign drifts into sales.** A recruiter mentions the firm's services to a hiring manager, and the FCC carve-out is gone for the whole campaign. Check: purpose is locked per campaign, staffing BD is logged as sales, and the purpose declaration covers follow-ups, not just the first call.
6. **Texts treated as exempt after Steidinger.** The ruling binds only the Seventh Circuit, and state laws cover texts. Check: SMS gets the same DNC verdict as voice, and rule 8 runs before any text goes out.
7. **An opt-out lost between channels.** A stop request sent by email or made on a voice call never reaches the texting tool. Check: route every reply that asks you to stop, keyword or not, to a person, and get it onto the internal list well inside the 10-business-day window.

> **Watch out:** Evidence is not a defense
>
> Querying the RND for numbers with no consent date fills the record with reassuring "No" results that protect nothing. Leave those rows unqueried and let rule 6 grade them.

> An RND query on a cold number produces evidence, not a defense.

Clearance failures are expensive. The TSR civil penalty is set per violation, and the figure in my sources is $51,744. Texas counts each call or text as a separate violation. The cost scales with the length of the list, not with how many mistakes you made.

## Sign-off checklist and keeping the standard current

Before a load goes live, the ops lead confirms every item below and signs the load header. Then, on a fixed schedule, the team re-checks the parts of the law that are still moving.

#### Before the load goes into the dialer or texting tool

- [ ] Every row has a line type, a lookup date, and a switchboard flag.
- [ ] Every row has both an area-code state and a claimed residence state, with unknown written in where needed.
- [ ] The campaign has one signed purpose declaration, and staffing business development is logged as sales.
- [ ] The national registry download is no more than 31 days old and covers every area code in the load.
- [ ] Every row has a scrub date and an expiry date, shortened where a verified state rule requires it.
- [ ] Zero internal DNC matches remain in the dialable set.
- [ ] Every row with a consent date has a logged RND result, and no row without one was graded on an RND result.
- [ ] Every row has a verdict and the number of the rule that fired.
- [ ] The dialer refuses expired rows, enforces the stricter state's hours, and caps calls at 3 per 24 hours where Table C applies.
- [ ] The texting tool sends an opt-out confirmation within 5 minutes, and non-keyword stop requests route to a person.
- [ ] The evidence record is stored where it will survive five years and a change of dialer.

Re-check these quarterly, and whenever a complaint or a new state law comes in:

- **The text-message split.** Steidinger and Howard interpret different subsections, and the district courts are still split. Follow a TCPA-focused litigation source such as TCPAWorld. The "texts are calls" rule stays in place until both the federal and state picture change.
- **The unverified cells in the state table.** Read the statutes for Oklahoma's scrub interval and hours, Washington's cap and text coverage, and Texas hours and caps. Replace each "unverified" with a citation or keep the strictest assumption.
- **The business-mobile question.** If a court rules on whether a business-used mobile is residential, revisit rule 5 with counsel. Until then, every mobile is residential.
- **The revocation rules.** The 10-business-day revocation window is in force. The FCC has waived the "revoke-all" provision, which is under reconsideration. Check its status before you change how opt-outs propagate across campaigns.
- **Registry subscription and fees.** Access is priced per area code with an annual cap, and the schedule changes each fiscal year. Re-confirm that coverage matches the area codes you actually dial.
- **Penalty figures.** Penalties are adjusted over time. Re-check the current TSR figure before using it in a risk memo.

Rule 5's consent exception, the Texas registration question, and your dialer definition all need counsel who knows telemarketing law. If you're filling that role in-house, Refolk can find in-house counsel at US fintech companies who specialise in it, and a reviewer who knows the rules can make the standard stricter or looser where your program needs it.

## Frequently asked questions

### Can you cold call cell phones B2B?

Not on the B2B exemption alone. The TSR exempts most business-to-business calls from its do-not-call rules, but the TCPA's registry protection covers residential subscribers, and the FCC applies it to wireless numbers. I found no source that settles whether a mobile used for business counts as residential, so this standard treats every mobile as residential. For sales, a registered mobile is Suppress. An unregistered mobile with no consent record is Hand-Dial Only.

### How often should you scrub a call list against the Do Not Call Registry?

Use a national registry download that is never more than 31 days old. Both the FTC and the FCC set that limit. Give each row an expiry date 31 days after its scrub, and have the dialer refuse rows that have expired. Check the internal do-not-call list at dial time as well, because opt-outs come in daily. State intervals vary by state, so read the statute for every state you dial.

### Do I need to check the Reassigned Numbers Database before calling?

Only for numbers where you have a consent date. You submit the number with the date consent was obtained, and the database tells you whether the number has been permanently disconnected since then. A 'No' may qualify you for the safe harbor. 'Yes' or 'No data' means no safe harbor. A cold sourced number has no consent date, so the query proves nothing useful, and the safe harbor excludes callers who never had consent anyway.

### Do Do Not Call rules apply to text messages in B2B outreach?

Assume they do. The federal circuits are split. The Seventh Circuit held that texts are not calls under the private right of action in Section 227(c)(5), and the Ninth Circuit held that a text is a call under Section 227(b). State laws, including Texas SB 140, expressly cover sales texts, and FCC enforcement is unaffected. This standard gives a text the same do-not-call verdict as a voice call.

### Is a recruiter calling a candidate a telephone solicitation?

Under the FCC's long-standing position, it is not, as long as the person called is not asked during or after the call to buy, rent, or invest in anything. That gets the call past the registry but not past dialer rules: prerecorded job recruitment calls to cell phones need express consent. If the call pitches staffing services to a client company, it is a sales call and is graded as one.

### What are the state do not call list scrub requirements?

They differ by state, and I could not find a primary-source table of scrub intervals. One vendor says Oklahoma requires a 30-day scrub, but I have not checked that against the statute. Florida, Oklahoma, and Maryland cap solicitation calls at 3 per 24 hours, and sources disagree about whether their B2B carve-outs apply. Record two state fields for each number, apply the stricter state, and read each statute yourself.

---

*From the Refolk guide library. I revise these guides rather than replacing them, so the current version is always at https://www.refolk.ai/guides/dial-list-clearance-standard*