A life insurance producer is scheduling outbound calls to prospects and former clients for the upcoming week. The producer must adhere strictly to the Telephone Consumer Protection Act (TCPA) and National Do Not Call Registry regulations. Which of the following planned calls are legally permissible? (Select all that apply.)
- A call at 10:00 AM local time to a prospect who requested a term life insurance quote online 45 days ago, even if the prospect is on the National Do Not Call Registry.Answer
- A call at 6:00 PM local time to a former client whose whole life policy lapsed 15 months ago, provided the client has not requested to be placed on the agency's internal Do Not Call list.Answer
- CA call to a purchased lead whose phone number was checked against the National Do Not Call Registry 45 days ago and was not listed at that time.
- DA call made at 9:15 PM the recipient's local time to a current policyholder to cross-sell an additional annuity product.
Answer
The permissible calls are the 10:00 AM call to the prospect who inquired 45 days ago, and the 6:00 PM call to the former client whose policy lapsed 15 months ago.
The correct options are permissible because federal regulations allow telemarketers to call consumers they have an Established Business Relationship (EBR) with, despite the Do Not Call Registry. This EBR extends to 18 months from the date of the last transaction (such as a lapsed policy) or 3 months from a consumer inquiry or application. Both compliant calls also fall within the required 8:00 AM to 9:00 PM local time window.
Step-by-Step Solution
Key Concept
TCPA and National Do Not Call Registry Exceptions and Rules