Compliance in insurance outbound sales is not a one-time setup — it is a pre-campaign, during-campaign, and post-campaign discipline. The agents who stay cleanest do not have better lawyers. They have a habit of checking the right things at the right time before problems accumulate into exposure.
Pre-Campaign Checklist
List Verification
- Active status check run on all records within the last 30 days
- Federal DNC registry scrub completed (records updated within 31 days per TSR safe harbor)
- State DNC scrub completed for all states in the campaign
- Litigator flag check completed (known TCPA plaintiffs removed)
- Line type verification completed (mobile vs. landline separated)
- Reassigned Number Database (RND) check completed for ATDS campaigns
- Internal DNC suppression list applied
- Verification date recorded on all records
Consent Documentation (For ATDS Campaigns)
- Prior express written consent available for every mobile number in the ATDS campaign queue
- Consent records name your specific agency (not a third-party aggregator)
- Consent records include timestamp, IP address (for web forms), and phone number
- Consent was actively given (unchecked checkbox, not pre-checked)
- Consent is not older than 18 months without re-affirmation
- Consent is stored at the record level, producible on demand per FCC 23-107
Dialer Configuration
- Time zone enforcement enabled (8 AM - 9 PM local time at called party's location)
- Arizona DST exception handled separately during March-November
- Abandoned call rate below 3% threshold for predictive/ATDS campaigns
- Caller ID number registered and tested (not flagged as spam)
- Call recording enabled with two-party consent disclosure for applicable states
Agent Preparation
- All agents have reviewed DNC request handling procedure (same-day internal DNC entry required)
- All agents have reviewed time zone compliance protocol
- Two-party consent state disclosure scripted and trained
- All agents are currently licensed in all states in the campaign
During-Campaign Checklist (Weekly)
Compliance Metrics
- DNC request rate from live conversations — above 3% triggers demographic or opener review
- Litigator flag check on any new numbers added mid-campaign
- Caller ID reputation check (YouMail, Hiya) — weekly minimum
- Abandoned call rate review for ATDS campaigns — stays below 3%
Agent Compliance Behavior
- Internal DNC entries are being made same-day (spot-check timing)
- Two-party disclosure is being delivered on first call in applicable states
- No attempts being made outside 8 AM - 9 PM local windows
List Health
- Dead number rate tracking — above 15% triggers re-verification
- Average list age review — above 60 days triggers partial re-verification
- Re-engagement queue re-verification completed for resurfacing records
Post-Campaign Checklist
Record Keeping
- Call records retained with timestamps, phone numbers, and outcomes (minimum 5 years per TSR)
- Internal DNC list updated with all requests from campaign (5-year retention)
- DNC scrub records preserved showing date of scrub and registry used
- Consent documentation archived for all numbers in ATDS campaigns
- Litigator flag check records preserved
List Archival
- Non-converting records with status and attempt count logged before archiving
- Re-engagement dates set on Dead records (90 days default)
- Explicit opt-outs permanently suppressed (not subject to re-engagement)
- List age documented for re-verification timing
Quick Reference: Retention Requirements
- Call records: 5 years (FTC TSR 16 C.F.R. 310.5)
- Internal DNC list entries: 5 years from date of request
- DNC scrub records: 5 years from campaign date
- ATDS consent documentation: 5 years from consent date
- Litigator flag check records: 5 years from campaign date
Automate most of this checklist by scanning your list before every campaign at cleanleads365.com/scan-my-list.
References
- Federal Trade Commission. (2003). Telemarketing Sales Rule. 16 C.F.R. Part 310. Record retention requirements.
- Federal Communications Commission. (2024). FCC 23-107. Consent documentation requirements. TCPA rules.
- FCC. (2024). Reassigned Numbers Database. ATDS campaign pre-scrub requirement.
