Keep the record, not just the list
16 CFR 310.5 lists eleven categories of records, retained five years. Two of them are the do-not-call ones, and those are the two software can genuinely hold — dated, tamper-evident, and exportable the day someone asks.
The registry itself is nearly free — the FTC charges $82 an area code and the first five cost nothing. What is hard is proving, eighteen months later, that you consulted it before you called, that you kept your own list, and that neither has been edited since.
That is a records problem, not a data problem. It is what this is.
Four records
Two of these are categories the rule names outright — 310.5(a)(10) and (a)(11). The other two are ours: the scrub log and the cycle clock, kept because the safe-harbor condition at 310.4(b)(3)(iv) asks you to maintain records documenting the process, not just to run it. The other nine categories belong in your dialer and CRM.
Registry accesses
16 CFR 310.5(a)(11)Who accessed the national registry, the date, the SAN used, and the campaign it was for. Four fields — that is the entire record the rule asks for. It works whether you download the registry yourself under your own SAN or we do it for you.
Your entity-specific list
16 CFR 310.5(a)(10)Everyone who asked you not to call: the number, who they are, the seller and telemarketer involved, what was being offered, and the date they asked. Removing someone marks the entry withdrawn rather than deleting it, so a question about a call made last March is still answerable.
Every scrub
When it ran, how many numbers, what was suppressed and why. Each result carries a signed receipt whose hash you can recompute from the response — so years later your copy and our record can be matched against each other.
The 31-day clock
How old your last recorded registry access is, and how long before it passes the 31-day mark the FTC expects. Stated as the age of the record, because whether a given call was inside the window depends on when you called.
The part most vendors leave out
A page that lists only what a product can do leaves you to find the gaps after you have signed. These are the gaps.
We do not tell you a call is lawful
No endpoint tells you a call is permitted. Whether a call complied depends on when you placed it, whether an established business relationship applied, whether you hold prior express written consent, and which state rules were in force — none of which we can see. We report what we found and stop there.
We do not sell you the national registry
It is not ours to sell. You subscribe directly with the FTC and share your Subscription Account Number with us as your service provider; the first five area codes are free and the whole country is $22,626 a year. We charge for the record, not the list.
We do not keep the rest of your telemarketing records
16 CFR 310.5(a) lists eleven categories. We hold two of them. The heaviest, (a)(2), is a record of every call with ten sub-fields — caller ID transmitted, script used, disposition, transfer target — and it can only be produced by whatever places your calls. Any vendor implying their product satisfies 310.5 in full is either selling a dialer or overstating.
We do not hold state or known-litigator lists
Ten states run a list you have to obtain separately, each with its own fee and publication cycle, and the litigator lists are commercial datasets we have not licensed. Every scrub result names the lists it checked and the lists it did not, in the same response — not in a footnote.
Line type is allocation-based, not live
We classify a number by the carrier its block was allocated to — a Verizon Wireless block is mobile, a Pacific Bell block is landline, a Bandwidth.com block is VoIP — and every verdict names that basis. Measured on the full NANPA file: 87% of prefixes classify, the rest say unknown rather than guessing. What this cannot see is porting: a number moved to another network keeps its digits. Wireless status drives the consent rules, so for numbers where it matters, a live HLR query is the authoritative check.
We do not offer a guarantee or an indemnity
Some vendors do — PossibleNOW markets DNCSolution with a '100% compliance guarantee'. We will not, because whether a call complied turns on when you placed it and what consent you held, and no vendor can see either. Responsibility rests with the seller and the telemarketer (16 CFR 310.5). What we provide is the record you would need to show what you did.
Compliance — $149/month
- 25,000 universal credits a month
- Unmetered scrubs against your own suppression list, with signed receipts
- Registry checks (state DNC + litigator) at 30 credits each — we buy that answer per call
- Registry access log — 16 CFR 310.5(a)(11)
- Five-year record retention, tamper-evident
- 31-day cycle tracking, safe-harbor export as PDF and CSV
- 10 lookups/second
DNC scrubs cost no credits on this plan — elsewhere in this market a scrub runs 10 credits every time. You are paying for the record and its retention, not for the questions.
Related: screening coverage · state do-not-call lists · compliance guides · API versioning policy