TCPA compliance for outbound dialing

Operator-perspective guide to the Telephone Consumer Protection Act — what's required, what's enforced, what hits dialing operations.

The Telephone Consumer Protection Act (TCPA, 1991, codified at 47 U.S.C. § 227) is the foundational US federal law on outbound calling. Its enforcement floor is 47 CFR § 64.1200. This page is operator-perspective — not legal advice. Talk to a telecom attorney before any high-volume program.

What TCPA actually requires

1. Time-of-day windows

No calls before 8am or after 9pm in the called party's local time. Use VICIdial's Local Call Time setting per campaign. The lead's area code → local time mapping is built in.

2. DNC respect (federal + internal)

Honor the federal Do Not Call registry (DNC.gov) AND your internal opt-outs. VICIdial supports both via the vicidial_dnc table — load the federal list scoped to campaign_id='all' for global enforcement.

See the DNC compliance guide.

3. Drop-rate cap

≤ 3% abandoned calls per campaign on a 30-day rolling window. Abandoned = no live agent within 2 seconds of the lead picking up. VICIdial's Drop SLA setting enforces the timer. The percentage is your responsibility to monitor.

4. Caller ID accuracy

The number you display must be a number you control + answer. Spoofing is a separate criminal statute (TRACED Act, 2019) but TCPA also requires CLI accuracy.

5. Reassigned-Numbers Database checks

Mandatory since 2021 for any call made under "express consent" footing. Pre-clean your lists against the FCC's RND before loading into VICIdial. See reassigned-numbers in glossary.

6. Express written consent for autodialed calls

Calls placed via predictive dialer to a phone number require prior express written consent specific to your business. The 2024 FCC ruling ended the "lead-form-with-50-checkboxes" pattern — consent must name a single seller.

7. Opt-out within 10 business days

The 2025 ruling: "stop", "stop calling", any clear cessation request via any channel must be honored across all channels for that consumer.

Penalties

$500 per call for negligent violations
$1,500 per call for willful violations
Class actions can scale into seven figures fast

Operational checklist

[ ] Local Call Time set on every campaign
[ ] Drop SLA = 2.0 seconds, monitor abandonment % daily
[ ] Federal DNC loaded into vicidial_dnc with campaign_id='all', refreshed monthly
[ ] Internal DNC enforced (Use Internal DNC = Y)
[ ] Lists pre-cleaned against the RND
[ ] Caller ID is a DID you own
[ ] Consent records stored with timestamp + IP + form text
[ ] Opt-out workflow tested

Where VICIfast helps

We don't do TCPA compliance for you. But we make it easier:

Per-customer audit log of every action — your discovery defense
Daily snapshots so dial logs are recoverable for litigation
Region pinning so EU calls live on EU servers (GDPR overlay)
TLS on every endpoint that handles personal data
VICIdial Local Call Time, Drop SLA, and Use Internal DNC all configurable per campaign