The 31-day rule, and why it is measured from the call
Safe harbour requires registry data obtained no more than 31 days before the call is made — which is not the same as scrubbing every 31 days.
The requirement appears inside the safe harbour provision, as one of six conditions. The wording is precise and the precision matters.
The seller or a telemarketer uses a process to prevent telemarketing to any telephone number on any list established pursuant to § 310.4(b)(3)(iii) or 310.4(b)(1)(iii)(B), employing a version of the “do-not-call” registry obtained from the Commission no more than thirty-one (31) days prior to the date any call is made, and maintains records documenting this process;
16 CFR 310.4(b)(3)(iv)
"Prior to the date any call is made" anchors the clock to the call, not to your calendar. A monthly download on the first of each month leaves the last days of a 31-day month outside the window. Teams that schedule a refresh every 31 days sharply are, by construction, at the edge on the last day of every cycle.
The second half of the sentence gets less attention and is doing just as much work: "and maintains records documenting this process". Downloading the registry on time is not enough on its own; the condition asks you to be able to show that you did. That is a recordkeeping obligation sitting inside a scrubbing requirement.
This is why our dashboard reports the age of your last recorded registry access rather than a yes-or-no verdict. Whether a given call was inside the window depends on when you placed that call, which we do not know. The age of the record we do know, and that is the fact we can state.
This page quotes the regulation and describes what it says. It is not legal advice, and whether any particular call complied depends on facts we do not hold. Talk to a lawyer about your own programme.