Calling windows, consent and DNC for insurance call floors

An insurance call floor lives or dies on contact rate, and contact rate tempts people to cut corners. The rules below exist because the corners have been cut before. They are also, almost all of them, things a system can check before a number is ever dialed, which is far cheaper than training every new producer to remember them.

Why a floor needs rules, not reminders

The federal Telephone Consumer Protection Act (TCPA) lets consumers sue for each unlawful call or text, with statutory damages per violation. The Telemarketing Sales Rule (TSR), enforced by the FTC, adds its own requirements for telemarketing calls. On top of both sit state laws, several of them stricter than federal rules. A floor making thousands of dials a week multiplies any mistake by the same number.

Calling windows

Federal rules limit telephone solicitations to between 8 a.m. and 9 p.m. in the called person's local time. That last part is what catches floors out: the window belongs to the lead, not to your office. A floor in Florida calling a lead in California at 9 a.m. Eastern is calling at 6 a.m. Pacific.

Some states set narrower windows or limits on how often you may call. Two examples:

Other states restrict calls on certain holidays or Sundays, or have their own registries. Work out the lead's time zone from their state and ZIP code rather than the area code alone, since people keep their numbers when they move.

Consent

Calls made with an autodialer, or with an artificial or prerecorded voice, to a mobile phone for marketing purposes require the consumer's prior express written consent. That means a written (including electronic) agreement that clearly authorizes the seller to call that number with marketing calls, and makes clear that consent is not a condition of purchase.

• Keep the evidence with the lead. Services such as TrustedForm and Jornaya record the consent event on a web form and give you a certificate. A certificate you cannot find when a complaint arrives is worth very little.
• Match the seller. Consent should name, or clearly cover, the business that is calling. In 2023 the FCC adopted a rule requiring consent to be given to one seller at a time; a federal appeals court vacated that rule in January 2025. Lead buyers should still check that their vendor's consent language covers them.
• Consent can be withdrawn in any reasonable way, not only by the method you prefer. A producer hearing "stop calling me" on a call is a revocation.

Do not call

There are three lists a floor has to respect:

1. The National Do Not Call Registry. Telemarketers must check their lists against it at least every 31 days. An established business relationship can be an exception: generally up to 18 months after the consumer's last purchase or transaction, or 3 months after an inquiry.
2. State do-not-call lists, where a state keeps its own.
3. Your own internal list. Anyone who asks your agency not to call again must be put on it and honored across every producer and every campaign. FCC rules set an outer limit on how long that may take, recently shortened to 10 business days. Better systems make it immediate.

Dialers, voicemail and abandoned calls

Predictive and parallel dialers call more numbers than there are free agents, so some answered calls have nobody to take them. The TSR treats these as abandoned calls and offers a safe harbour only if, among other things:

• No more than 3% of answered calls in a campaign are abandoned, measured over 30 days.
• Each call rings for at least 15 seconds or four rings before it is disconnected.
• When no agent is free within two seconds of the greeting, a recorded message plays that identifies the seller and gives a number to call back.

Prerecorded voicemail drops are prerecorded calls. Treat them as needing prior express written consent before you leave one on a mobile phone.

Caller ID must show a number that a consumer can call back during business hours. Numbers that are flagged as spam by phone carriers lose contact rate quickly, so watch their health and rotate them responsibly rather than burning through them.

Texting

The TCPA applies to text messages as it does to calls. Business texting in the United States also runs on registered 10DLC campaigns, which the phone carriers require before they will deliver application-to-person messages at volume.

• Honor STOP and similar replies straight away, and confirm the opt-out once.
• Respect quiet hours in the recipient's local time, just as with calls.
• Keep texting consent separate from calling consent, and keep a record of both.

Recording calls

Federal law allows recording when one party to the call consents. A number of states, including Florida and California, require the consent of everyone on the call. A short disclosure at the start of every recorded call is the simplest way to cover a floor that calls across state lines.

A floor checklist

1. Work out every lead's time zone from state and ZIP before it enters a campaign.
2. Block dials outside the lead's window, using the strictest rule that applies.
3. Store a consent certificate with every purchased lead, and do not dial leads without one.
4. Scrub against the national and state registries at least every 31 days.
5. Make the internal do-not-call list immediate and agency wide, across calls and texts.
6. Keep parallel dialing inside the 3% abandonment safe harbour, with the required message.
7. Only drop prerecorded voicemail where you have prior express written consent.
8. Disclose recording at the start of every recorded call.
9. Review the compliance report weekly, not when a complaint arrives.

How Vora enforces it

Vora checks every dial before it happens rather than trusting people to remember. Each lead says in plain words whether it can be called right now, and why not.

• State calling hours and limits are built in and kept up to date by Vora, and checked against the lead's own time zone.
• Leads without a consent certificate are marked Needs consent and are not dialed until consent is on file.
• Do-not-call entries and opt-outs are shared across texting and calling, for the whole agency.
• Parallel dialing manages abandonment, and voicemail drop is limited to leads with written consent.
• Recorded calls play a consent disclosure when the call is bridged.
• Texts that are not replies go out only between 8 a.m. and 8 p.m. in the client's local time.
• Compliance and caller ID health reports show where the floor is drifting.