Practical guidance for insurance agents, not legal advice. Laws change faster than blog posts; your counsel beats our library. Last reviewed: July 16, 2026.
Not safely. Purchased data carries no consent, and consent is what unlocks automated calling technologies. A human manually dialing each number with a live voice is the one method that is lawful on purchased leads everywhere. Prerecorded messages, AI voices, ringless voicemail, and marketing texts are off the table entirely, and dialer automation is a state-by-state minefield.
Manual dial + live voice: the lawful lane. A person selects the number, initiates the call, and speaks. No federal consent requirement applies to the technology, and every state’s rules can be satisfied with windows, caps, and scrubbing. This is the workflow every DAITA DRIVE file is designed and contractually sold for, and the DRIVE Score exists to make those manual dials count.
Power and click-to-dial systems: the gray zone. Under federal law after the Supreme Court’s Facebook v. Duguid decision, most list-based dialers fall outside the autodialer definition, which requires random or sequential number generation. But two problems remain. Several states define automated dialing more broadly (Florida’s “automated selection and dialing” standard can capture systems federal law ignores). And a 2025 Supreme Court decision, McLaughlin v. McKesson, freed lower courts from decades of FCC interpretations, so federal answers you relied on last year can now vary by courtroom. Without consent, treat dialer automation as high-risk; one-click human-initiated dialing is the defensible configuration.
Prerecorded, AI voice, ringless voicemail, and texts: off the table. Prerecorded and artificial-voice marketing calls require prior express written consent, and the FCC confirmed in 2024 that AI-generated voices count as artificial. Ringless voicemail is treated as a call. Marketing texts require written consent and several states regulate them like calls. Purchased data has none of that consent, which is why our contracts prohibit all four uses, with no winks. More on that in what “consented leads” really means.
Two reasons. It protects you: an agent who robodials a purchased list is the easiest TCPA defendant in America, and no short-term dialing efficiency survives one statutory-damages calculation. And it protects the data: every agent who burns a market with robocalls poisons that territory for the compliant agents working it. The manual lane is slower per dial and dramatically better per outcome, which is the entire premise of scoring: fewer, better calls.
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.
“Compliant” describes a configuration, not a product. The same platform can be lawful in human-initiated mode and unlawful blasting prerecorded drops. Ask how the call is initiated, whether any prerecorded or AI audio plays, and what consent the vendor assumes you have, then check that assumption against data that has none.
AI is fine everywhere except the voice on the line: prioritizing who to call, prepping the opener, logging outcomes, drafting follow-up mail. The line the law draws is the artificial voice speaking to a consumer without written consent. Assist the human; never replace the human.
Human-initiated, one-at-a-time dialing from a CRM is the standard defensible setup, and it is exactly how DRIVE files are meant to be worked: hot-window leads first, opener on screen, one real conversation at a time.