What the Telemarketing Sales Rule asks you to keep, in full
16 CFR 310.5(a) lists eleven categories of records, retained five years. Most of them belong in your dialer and CRM, not in a compliance tool.
Compliance vendors tend to describe the recordkeeping rule as though it were about do-not-call lists. It is broader than that. Section 310.5(a) opens with the retention period and then lists eleven categories.
Any seller or telemarketer must keep, for a period of 5 years from the date the record is produced unless specified otherwise, the following records relating to its telemarketing activities:
16 CFR 310.5(a)
The heaviest of the eleven is (a)(2), a record of each telemarketing call. It has ten sub-fields of its own: who placed it, for which seller, what was offered, consumer or business, outbound or not, prerecorded or not, the calling and called numbers with date, time and duration, the script used, the caller ID number and name transmitted along with proof of authorisation to use them, and the disposition of the call including where it was transferred.
That record is produced by whatever places your calls. No lookup API can generate it, and any vendor implying their product satisfies 310.5 in full is either selling a dialer or overstating. Two of the eleven categories are the do-not-call ones, and those are the two a compliance record can genuinely hold.
A record of each person who has stated she does not wish to receive any outbound telephone calls made on behalf of a seller or charitable organization pursuant to § 310.4(b)(1)(iii)(A) including: the name of the person, the telephone number(s) associated with the request, the seller or charitable organization from which the person does not wish to receive calls, the telemarketer that called the person, the date the person requested that she cease receiving such calls, and the goods or services the seller was offering
16 CFR 310.5(a)(10)
A record of which version of the Commission's “do-not-call” registry was used to ensure compliance with § 310.4(b)(1)(iii)(B). Such record must include: (i) The name of the entity which accessed the registry; (ii) The date the “do-not-call” registry was accessed; (iii) The subscription account number that was used to access the registry; and (iv) The telemarketing campaign for which it was accessed.
16 CFR 310.5(a)(11)
Two details in the rest of the section are worth knowing. Paragraph (b) allows you to keep these records "in the same manner, format, or place as they keep such records in the ordinary course of business" — there is no prescribed file format, and a vendor claiming their format is the compliant one is inventing a requirement. Paragraph (c) is the sharp end: failing to keep any required record completely and accurately "is a violation of this part". The recordkeeping is not paperwork attached to the obligation; it is part of the obligation.
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.