TCPA Best Practices: Complete DNC Scrubbing Workflow Guide
Master telephone compliance with our comprehensive guide to Do Not Call registry scrubbing, list management workflows, and TCPA best practices. Protect your business from $51,744 per violation penalties.
Why DNC Scrubbing Matters More Than Ever
CRITICAL: January 27, 2025 Rule Change
The FCC's new TCPA One-to-One Consent Rule is now in effect. Combined with existing DNC regulations, improper contact list management can result in $51,744 per violation. A single mass text campaign to 100 numbers on the DNC registry could cost you $5,174,400 in penalties.
The National Do Not Call (DNC) Registry is not optional, and ignorance is not a defense. Whether you're a fire restoration contractor, public adjuster, real estate professional, or any business using FirstLeads data, you must scrub your contact lists against the DNC registry before making any phone calls or sending texts.
This comprehensive guide walks you through the complete DNC scrubbing workflow, monthly maintenance procedures, record-keeping requirements, and integration strategies to ensure 100% TCPA compliance.
What is the National Do Not Call Registry?
The National Do Not Call Registry is a federal database managed by the Federal Trade Commission (FTC) containing phone numbers of consumers who have opted out of receiving telemarketing calls. Once a number is registered, it remains on the registry permanently unless the consumer removes it.
Key DNC Registry Facts:
- Registry Size: Over 245 million phone numbers
- Permanent Registration: Numbers never expire unless consumer removes them
- Includes: Landlines, cell phones, VoIP numbers
- Coverage: All 50 states, U.S. territories
- Enforcement: FTC, FCC, state attorneys general
- Penalties: Up to $51,744 per violation (adjusted annually for inflation)
What Types of Calls Are Covered?
- Sales Calls: Any call offering goods or services for sale
- Robocalls: Automated or pre-recorded messages
- Text Messages: SMS and MMS marketing messages
- Ringless Voicemail: Direct-to-voicemail drops (legally questionable)
Penalties: What's at Stake?
Federal Penalties
- Up to $51,744 per violation
- Treble damages for willful violations
- Class action lawsuits from consumers
- Injunctions prohibiting future calls
State Penalties
- California: $2,500 per violation
- Florida: $10,000 per violation
- Texas: $11,000 per violation
- New York: Additional state fines
Real Penalty Examples:
ADT Security Services (2018)
Penalty: $16 million
Violation: Millions of robocalls to DNC-registered numbers
Dish Network (2017)
Penalty: $280 million
Violation: 66 million illegal telemarketing calls
Caribbean Cruise Line (2013)
Penalty: $3.4 million
Violation: Illegal robocalls to DNC-registered consumers
Step-by-Step DNC Scrubbing Workflow
Follow this proven 10-step workflow to ensure 100% TCPA compliance for all fire damage leads. This process should be completed every time you acquire new contact data from FirstLeads or any other source.
Register for DNC Access
Before you can scrub your lists, you must register for access to the National DNC Registry at www.telemarketing.donotcall.gov.
Registration Requirements:
- Business name and address
- Valid business email address
- Credit card for subscription fees
- EIN or Tax ID number
Annual Subscription Costs:
- Area Code Access: $68 per area code per year
- 5-Area Code Bundle: $172 per year (save $168)
- National Access: $19,580 per year (all area codes)
Export Your Fire Leads Contact List
After using FirstLeads skip trace feature to unlock property owner contact information, export your contact list in the correct format for DNC scrubbing.
Required Format (CSV or TXT):
555-123-4567 555-234-5678 555-345-6789 555-456-7890
Format Requirements: One phone number per line, 10-digit format (no formatting), no headers or extra columns.
Access the DNC Scrubbing Portal
Log in to the National DNC Registry portal and navigate to the scrubbing section.
- Go to www.telemarketing.donotcall.gov
- Click "Access the Registry" → "Telemarketers & Sellers"
- Enter your username and password
- Navigate to "Scrub Lists" or "Check Registry"
Upload Your Contact List
Upload your fire leads contact list file to the DNC scrubbing portal.
File Upload Options:
- Manual Upload: Browse and select your CSV/TXT file
- API Integration: Automated scrubbing via API (advanced users)
- Batch Processing: Upload up to 25,000 numbers per batch
Processing Time:
Expect 5-15 minutes for processing depending on list size. The portal will email you when scrubbing is complete.
Download Scrubbed Results
Once processing completes, download two critical files from the portal.
Safe-to-Call List
Numbers NOT on the DNC registry. You may contact these property owners legally.
DNC-Registered List
Numbers ON the DNC registry. DO NOT CONTACT these numbers.
Use FirstLeads Litigator Scrubbing (Bonus Protection)
FirstLeads provides an additional layer of protection by automatically flagging contact information of known serial litigators who file TCPA lawsuits.
What is Litigator Scrubbing?
Litigator scrubbing identifies phone numbers belonging to individuals with a history of filing TCPA lawsuits. These are "professional plaintiffs" who register on DNC lists specifically to sue businesses.
FirstLeads Integration: When you unlock contact info via skip trace, litigator flags are automatically shown in the contact details. Avoid contacting these individuals even if they're NOT on the DNC registry.
Update Your CRM/Contact Database
Import the safe-to-call list into your CRM and mark DNC-registered numbers as "Do Not Contact."
CRM Best Practices:
- Flag DNC Numbers: Create a custom field "DNC Status" = TRUE/FALSE
- Suppress Calling: Configure CRM to block calls to DNC-flagged numbers
- Add Tags: Tag records with "DNC Scrubbed - [Date]"
- Litigator Flag: Create additional field for litigator warnings
- Audit Trail: Log who scrubbed, when, and scrubbing results
Begin Contacting Safe-to-Call Leads
You may now legally contact property owners on your safe-to-call list. Follow these additional compliance rules:
Calling Best Practices:
- Manual Dialing Only: No autodialers or robocalls without PEWC
- Identify Yourself: State your name, company, and reason for calling upfront
- Calling Hours: 8 AM - 9 PM local time (recipient's timezone)
- Opt-Out Mechanism: Honor immediate verbal opt-out requests
- Internal DNC List: Maintain your own opt-out list and scrub against it
Maintain Detailed Records
TCPA compliance requires comprehensive documentation. The FTC can audit your records at any time.
Required Documentation:
- DNC Scrubbing Logs: Date, time, list size, scrubbing results
- Scrubbed Files: Original list, safe-to-call list, DNC list
- Call Records: Who called, when, outcome, consent obtained
- Opt-Out Requests: Date, contact info, method of opt-out
- PEWC Documentation: Signed consent forms (if using autodialers)
Retention Period:
Keep all DNC scrubbing and calling records for at least 5 years. Some states require 7 years. When in doubt, keep records longer.
Schedule Monthly Re-Scrubbing
The DNC registry is updated daily. You must re-scrub your contact lists every 31 days or less.
Critical Compliance Requirement
Even if a number was safe to call yesterday, it could be registered on the DNC today. You must re-scrub your entire contact database at least every 31 days. Set up calendar reminders or automated scrubbing workflows to ensure compliance.
Monthly DNC Scrubbing Schedule Template
Consistency is key to TCPA compliance. Use this monthly schedule template to ensure you never miss a scrubbing deadline.
Recommended Monthly Workflow:
Export Full Contact Database
Download all phone numbers from your CRM in DNC-compatible format.
Upload to DNC Registry Portal
Submit list for scrubbing and wait for processing (5-15 minutes).
Download Results & Update CRM
Import safe-to-call list, flag new DNC numbers, update "Last Scrubbed" date field.
Contact Safe-to-Call Leads Only
Make calls, send texts, follow up. Track all opt-out requests immediately.
Mandatory Re-Scrubbing Deadline
Repeat the entire process. DO NOT skip this step.
Pro Tip: Automate with Calendar Reminders
Set up recurring calendar reminders on the 1st of every month with this checklist:
- Export contact database from CRM
- Upload to DNC registry portal
- Download scrubbed results
- Update CRM with new DNC flags
- File documentation in compliance folder
- Schedule next month's scrubbing
State-Specific DNC Registries
Some states maintain their own Do Not Call registries in addition to the federal list. If you're contacting property owners in these states, you must scrub against both the national and state registries.
States with Additional DNC Registries:
Multi-State Compliance Strategy:
- Identify which states your fire leads are located in
- Register for state DNC registries in those states
- Scrub against national registry first
- Then scrub against each applicable state registry
- Only contact numbers that pass BOTH federal and state scrubbing
Internal DNC List Management
Beyond the national and state registries, you must maintain your own internal Do Not Call list. This list includes anyone who has asked you specifically not to contact them, even if they're not on the federal registry.
Who Goes on Your Internal DNC List?
- Verbal Opt-Out Requests:
Anyone who says "don't call me again," "remove me from your list," or similar statements during a call.
- Email Opt-Out Requests:
Property owners who reply to emails asking not to be contacted.
- Written Opt-Out Requests:
Formal letters or forms requesting removal from contact lists.
- Hostile or Threatening Contacts:
Anyone who reacts negatively or threatens legal action.
- Litigators:
Professional plaintiffs identified by FirstLeads litigator scrubbing feature.
Internal DNC List Best Practices:
- Immediate Addition: Add opt-out requests to internal list within 24 hours
- Scrub Before Every Campaign: Check internal list before calling/texting anyone
- Permanent Retention: Never remove numbers from internal DNC list
- Document Everything: Note date, time, method, and reason for opt-out
- Company-Wide Sharing: Ensure all team members have access to internal DNC list
- Regular Audits: Quarterly review to ensure no suppressed numbers are contacted
Common DNC Scrubbing Mistakes to Avoid
These are the most frequent mistakes businesses make that lead to TCPA violations and penalties. Learn from others' errors.
Mistake #1: Scrubbing Only Once
The Error: Businesses scrub their contact list once when they first acquire leads, then never scrub again.
Why It's Dangerous: The DNC registry updates daily. A number that was safe to call 32 days ago could be registered today.
The Fix: Re-scrub your entire contact database every 31 days or less. Set calendar reminders.
Mistake #2: Not Checking State Registries
The Error: Scrubbing only against the national DNC registry and ignoring state-specific lists.
Why It's Dangerous: States like California, Florida, and Texas have additional penalties ($2,500-$10,000 per violation).
The Fix: Identify which states your leads are in, register for state DNC lists, and scrub against both federal and state registries.
Mistake #3: Poor Record-Keeping
The Error: Not documenting when lists were scrubbed or what the results were.
Why It's Dangerous: In TCPA lawsuits, the burden of proof is on YOU to show compliance. No records = no defense.
The Fix: Keep detailed logs of every scrubbing session (date, time, list size, results) and retain files for 5-7 years.
Mistake #4: Ignoring Verbal Opt-Outs
The Error: Not adding numbers to internal DNC list after verbal opt-out requests during calls.
Why It's Dangerous: Calling someone after they've asked not to be contacted is a slam-dunk TCPA violation.
The Fix: Create a process where all team members immediately report opt-out requests, and add numbers to internal DNC list within 24 hours.
Mistake #5: Using Autodialers Without PEWC
The Error: Using autodialers, robocalls, or mass texting without obtaining Prior Express Written Consent (PEWC).
Why It's Dangerous: Even if a number is NOT on the DNC registry, you need PEWC to use automated calling technology. The new One-to-One Consent Rule (Jan 27, 2025) makes this even stricter.
The Fix: Either (1) obtain individual PEWC from each property owner before calling, or (2) use manual dialing only. See our Legal Compliance Guide for PEWC requirements.
Automated DNC Scrubbing Tools
For businesses with large contact databases or high lead volume, manual DNC scrubbing every month becomes time-consuming. Consider these automated solutions to streamline compliance.
DNC.com
Automated scrubbing service with API integration for real-time compliance checks.
- Real-time DNC checks via API
- Federal and state registry scrubbing
- Litigator list included
Website: www.dnc.com
ScrubDNC
Bulk DNC scrubbing with automated monthly re-scrubbing and CRM integrations.
- Automatic monthly re-scrubbing
- Integrates with major CRMs
- State registry coverage
Website: www.scrubdnc.com
TelScrub
Enterprise-grade scrubbing solution with compliance reporting and audit trails.
- Enterprise compliance reporting
- Audit trail and documentation
- Multi-list management
Website: www.telscrub.com
Gryphon Networks
All-in-one compliance platform with real-time call blocking and litigator detection.
- Real-time call blocking
- Advanced litigator screening
- Call recording for consent proof
Website: www.gryphonnetworks.com
Choosing the Right Tool:
Consider these factors when selecting automated DNC scrubbing software:
- Contact Volume: How many leads do you process per month?
- CRM Integration: Does it connect with your existing CRM?
- State Coverage: Does it scrub state registries you need?
- Pricing Model: Per-scrub, monthly subscription, or API usage?
- Documentation: Does it provide audit-ready compliance reports?
- Litigator Lists: Are professional plaintiffs included?
TCPA & DNC Compliance Checklist
Use this comprehensive checklist to ensure you're following all TCPA and DNC best practices. Print and post in your office for reference.
Initial Setup (One-Time Tasks):
Monthly Tasks (Every 31 Days):
Before Every Calling/Texting Campaign:
After Every Call/Campaign:
Additional Resources
Official Government Resources
- National DNC Registry: www.telemarketing.donotcall.gov
- FTC TCPA Guidance: www.ftc.gov/legal-library
- FCC TCPA Rules: www.fcc.gov/tcpa
- FCC One-to-One Consent Rule (Jan 2025): FCC-23-111 Order
Legal Compliance Guides
- Complete Legal Compliance Guide for Fire Leads - TCPA, PEWC, DNC, CAN-SPAM, Privacy Laws
- FirstLeads Terms & Conditions - User responsibilities and legal obligations
- FirstLeads Privacy Policy - How we handle data and comply with CCPA/GDPR
Professional Assistance
- Telecommunications Attorneys: Consult with specialized TCPA attorneys if facing violations or complaints
- Compliance Consultants: Hire third-party compliance firms to audit your processes
- FirstLeads Support: Contact info@firstleads.ai with questions about compliance features
Final Thoughts
DNC scrubbing and TCPA compliance are not optional—they're mandatory if you want to stay in business. The penalties for violations are severe, and the FTC and FCC are actively enforcing these rules with record fines.
The good news? Compliance is straightforward if you follow the workflows and best practices outlined in this guide. Scrub your lists every 31 days, maintain detailed records, honor opt-out requests immediately, and use FirstLeads' litigator scrubbing feature for extra protection.
Fire damage leads represent incredible opportunities—$50K to $500K+ restoration projects with urgent need and insurance-backed financing. Don't let a preventable compliance mistake derail your business when the solution is this simple.
Ready to Build Your Compliant Fire Leads Pipeline?
Start with FirstLeads' real-time fire incident monitoring, use our skip trace feature to unlock property owner contact info, leverage our litigator scrubbing protection, and follow this DNC scrubbing workflow to stay 100% compliant.