Compliance guide

What Is DNC Scrubbing, and Who Has to Do It?

Practical guidance for insurance agents, not legal advice. Laws change faster than blog posts; your counsel beats our library. Last reviewed: July 16, 2026.

DNC scrubbing removes numbers on the National Do Not Call Registry (and state registries) from a calling list before anyone dials. Telemarketing law requires the scrub to be no more than 31 days old at the time of the call, which means scrubbing is a cycle, not a one-time event. Both your vendor and you have a role.

How big is the registry, really?

About 258 million numbers, which is most of the phone-owning population. On raw compiled data, a proper scrub removes the large majority of records from the callable universe. Sit with that number a moment, because it explains two things: why unscrubbed lists are so cheap, and why a seller advertising “millions of dialable records” without mentioning the registry is describing a lawsuit, not an asset.

The 31-day rule (and why the vendor’s scrub is not enough)

A scrub is a snapshot. Numbers join the registry every day, so the law requires your list to be checked against a version of the registry no older than 31 days whenever you call. A vendor’s scrub covers you on delivery day; your re-scrub covers you on dial day. Mature operations run both: scrub-on-purchase and scrub-on-dial.

⚠ One more wrinkle: access to the registry runs through a Subscription Account Number (SAN), and the FTC prohibits sharing one. Your data vendor’s SAN does not substitute for yours. The first five area codes are free; national coverage is capped at $22,626 for organizations that need it, and a local agency’s footprint usually costs little or nothing. Have counsel confirm your agency’s SAN obligations for your states and licenses.

The state registries most agents miss

Eleven states run their own do-not-call registries with separate scrub duties: Colorado, Florida, Indiana, Louisiana, Massachusetts, Missouri, Oklahoma, Pennsylvania, Tennessee, Texas, and Wyoming. A federal-only scrub is incomplete in all of them. Every DAITA DRIVE file is scrubbed against the federal registry and all eleven before delivery, with the scrub date printed on the certificate.

The third list: your own

Anyone who says “stop calling me” goes on your internal do-not-call list immediately and permanently, regardless of any registry. Under the FCC’s revocation rules, a consumer can revoke by any reasonable means and you must honor it promptly; keep records for five years. Our platform-level version: an opt-out to any DAITA DRIVE buyer suppresses that consumer across our whole network, so a number you were sold never comes back to bite someone else. Related: what is litigator scrubbing?

What ships with every DAITA DRIVE file

A dated scrub certificate covering the federal DNC registry and 11 state registries. Known-litigator screening. Wireless flags and local time zones on every number. Per-state calling windows and attempt caps attached. Sold for manually dialed, live-voice calling plus mail and door outreach, and never represented as anything else.

The only leads you can defend.

FAQ

The questions agents actually ask.

How often do I need to re-scrub a purchased list?

Every 31 days while you are still dialing it, against both the federal registry and any applicable state registries. Subscription DAITA DRIVE files arrive re-scrubbed monthly with a fresh certificate, which resets your clock on delivery.

What does a scrub certificate prove?

That a named list was checked against named registries on a stated date. In a dispute, it is the difference between demonstrating a compliance process and asking a court to take your word. Keep every certificate with its delivery file.

Are there exceptions for existing customers?

An established business relationship lets you call your own recent customers and inquirers despite the registry, within time limits. It never applies to a cold purchased list, so treat purchased data as fully registry-bound.