TCPA + dialing compliance
The non-legal-advice operator guide to TCPA, DNC, and reassigned-numbers checks.
This is operator guidance, not legal advice. Talk to a telecom attorney before going live with any high-volume outbound program.
What TCPA actually requires
The Telephone Consumer Protection Act (TCPA) is the federal statute. Its enforcement floor is 47 CFR § 64.1200. The rules that hit dialing operations hardest:
- Time-of-day: no calls before 8am or after 9pm in the called party's local time.
- DNC respect: federal DNC + your internal opt-out list, both must be honored.
- Caller ID accuracy: spoofing is a separate criminal statute (TRACED Act). Display a phone number you own + answer.
- Drop-rate cap: ≤ 3% abandoned calls per campaign per 30-day rolling window. Dropped = no live agent within 2 seconds.
- Identification: agents must identify themselves + the company within the first 30 seconds of a live call.
- Reassigned-numbers DB (US): RND check before any TCPA-regulated call. Mandatory since 2021.
State laws stack on top. Florida (FTSA), Washington, New York all add their own restrictions; some are stricter than federal.
What this means for VICIdial config
| TCPA requirement | VICIdial setting |
| ----------------------- | -------------------------------------------------------------- |
| Local call-time windows | Campaign → Local Call Time |
| Drop-rate cap | Campaign → Drop SLA = 2.0, Use Internal DNC = Y |
| Federal DNC | Load the Reassigned Numbers + DNC.gov data into vicidial_dnc |
| Internal DNC | Campaign → Use Internal DNC = Y |
| Caller ID | Campaign → Campaign CID (a number you own + answer) |
Recording laws (separate from TCPA)
Recording calls is regulated state-by-state, not federally. Two camps:
- One-party consent states (most): you (the agent) consent, you can record.
- Two-party consent states (CA, FL, IL, MD, MA, MT, NH, PA, WA, NV — partial): both parties must be informed.
Operationally: play a beep + announcement at call start, log the consent, and store a per-campaign "Recording Override" config.
Reassigned-Numbers Database
The FCC RND prevents you from being liable when you dial a number that's been reassigned away from the consent-giver. Cost: ~$0.0035 per check at volume. Required for any call you make under "prior express consent" footing.
Common workflow: pre-clean your list against the RND before loading into VICIdial. There are commercial services (Numeracle, Caller ID Reputation, Possible Now) that bulk-clean for you.
Litigator alert lists
Outside the regs themselves, plaintiff-attorney call traps exist. Lists of numbers known to file TCPA complaints. We strongly recommend buying a litigator-alert feed and pre-screening.
Documentation = defense
If you get sued, the question is "can you prove consent + compliance for this call?" Keep:
- The opt-in record (timestamp, IP, the form text shown)
- The dial log (VICIdial has this in
vicidial_log) - The recording (if recorded)
- The DNC checks performed (VICIdial logs internal DNC; federal DNC + RND should be logged externally)
VICIfast-side support
We don't do compliance for you, but we provide:
- Per-customer audit log of every action your team takes
- Daily snapshots so dial logs are recoverable for litigation
- Region pinning so EU calls live in EU servers (GDPR)
- TLS on every endpoint that handles personal data
If you need something specific for a regulator, ask — we'll see what's possible.