10-Step Year-end TCPA Compliance Checklist for Cold Calling Prospect Lists 

Cold calling hits differently when you know every number on your list has been checked for risk. You already know your outbound results depend on good data. What often gets pushed aside is the legal risk of dialing people who never asked to hear from you. As year-end approaches, your team is closing tickets, cleaning pipelines, and discussing next year’s targets. That is the perfect time also to clean and harden your prospect lists for TCPA compliance.

This checklist walks you through a practical, step-by-step process to follow before your agents start calling cold prospects in January. It focuses on what to do with the phone numbers you already have, so you reduce risk before the new year begins.

Searchbug tools that fit into this checklist

• DNC Check with four-point screening
• Reassigned Numbers API
• Advanced Phone Validator with timezone and state information

You can treat this guide as a working checklist for your team and your vendors.

How’s Cold Calling in December?  

Many teams slow down active outreach in December. Decision makers travel. Finance people focus on the year-end close. Budgets for new projects may be frozen until January.

That does not mean December is “dead” for cold calling. Some industries see better answer rates because people are at their desks trying to clear work before the holiday break. What often changes is the type of activity your sales and telemarketing teams can do.

When live connect rates are unstable, the list work finally gets attention. That makes December a smart month for:

• Scrubbing and enriching prospect lists
• Tightening consent records
• Restructuring lead segments
• Putting better TCPA controls in place before volume ramps up again

You do not want your first week of January to be the moment you realize your list was never screened against the National DNC, state lists, or the Reassigned Numbers Database.

Why Do You Need to Screen Phone Numbers Before Calling?  

TCPA risk is not going away. Numbers from the last two years show the opposite trend.

• One analysis found 1,683 TCPA cases filed in 2023, which was a 9.4% increase from 2022.
• Industry reporting based on WebRecon data shows 2,788 TCPA cases in 2024, a 67% jump from 2023, and more than 80% of those were class actions.
• Another legal update reported 507 TCPA class actions in just the first quarter of 2025, more than double the same period the year before.

Statutory damages remain up to $ 500 per call or text and up to $ 1,500 for willful violations, with no overall cap. Even a modest list, dialed at scale, can create exposure big enough to hurt or even shut down a smaller operation.

Class actions and settlements in the millions are not limited to the largest brands. Legal and insurance commentary notes that average TCPA settlements can reach multi-million-dollar levels and that small businesses are now frequent targets.

So if you are planning to increase outbound volume next year, year-end list work is not a nice-to-have project. It is a direct risk control step.

10-step TCPA Compliance Checklist   

You can use the following steps as an internal checklist. Treat each step as a gate. A phone number should pass each gate before it reaches an outbound campaign.

1. Confirm who is on your list and how they got there 

Start with clarity about the data itself.

• Separate current customers from pure prospects
• Tag leads from partners, list vendors, events, website forms, and old imports
• Treat any record with no clear source as high risk

If you do not know where a number came from, treat that contact as cold and assume you do not have consent. For some of you, this will shrink the dialable list, which may feel painful at first. It is still better than dialing people who have no connection to your business.

Action step

☐ Export your list and add fields for “source” and “relationship type” in your CRM or dialer. Force a value on every record before it moves forward.

2. Label every record for consent and internal DNC status  

Consent records are often scattered across tools. Web forms, landing pages, chatbots, and lead vendors all collect it in different ways. Before the new year starts, gather that information into one place.

• Mark whether you have express written consent to call or text.
• Mark whether you only have an inquiry or an established business relationship.
• Mark records that have opted out or complained to your team.

Your internal DNC list is as important as external lists. A person who told you “stop calling” should never appear in a new campaign just because they moved into a new segment or a new dialer.

Action step

☐ Create standard consent values in your system, such as “Express written,” “Inquiry only,” “No consent,” and “Opt out.” Make sure your dialer respects these tags.

3. Run a four-point DNC and TCPA Compliance risk screen on every number  

After internal checks, move to external lists. This is where Searchbug’s DNC Check helps.

For each number your team plans to dial, you want to know at least four things.

1. Is the number on the National Do Not Call Registry
2. Is it on any state DNC list that your campaigns must respect
3. Has the number been flagged as a frequent DNC complainer
4. Is the number linked to known TCPA litigators

Searchbug’s DNC Check pulls these four views together in a single result, so you do not juggle separate tools or spreadsheets. You can run this as a bulk scrub before the end of the year or wire it into your dialer or CRM with the DNC Check API.

How to use the result

• Treat consumer numbers on National DNC as “do not call” unless your legal team confirms a clear exemption
• Treat state list hits with extra care since many states now run separate enforcement programs.
• Treat known DNC complainers as “do not call” regardless of consent on file
• Treat TCPA litigator hits as “hard block” and remove them from all outbound activity

Action step

☐ Remove high-risk numbers on the list

☐ If you outsource calling to a vendor, add these rules into your contract and your QA program.

4. Check for reassigned numbers to enhance TCPA Compliance

Consent from the wrong person does not protect you. That is the point of the Reassigned Numbers Database.

When a number changes ownership, consent you collected from the previous owner no longer covers calls to the new owner. If you keep calling based on old consent, you can face TCPA claims even though you think you are contacting your own lead.

Searchbug’s Reassigned Numbers API checks your numbers against the official Reassigned Numbers Database and tells you whether a number has changed hands after a given consent date.

The API returns three possible responses.

• YES
  • The number has been reassigned after the consent date you sent in the request
  • Treat existing consent as no longer valid
  • Remove this number from auto-dial campaigns
  • Move it into a re-permission workflow if your legal team approves that approach

• NO
  • The database does not show a reassignment after the consent date you provided
  • Treat consent as still tied to the same subscriber as long as your other checks look good
  • Keep the number in your dialable list, but still respect DNC, litigator, and complainer flags

• NO_DATA
  • The database does not have enough information about this number and date
  • This can happen when a carrier does not report data or when the number is new
  • Treat these records as higher risk than a clean “NO” result
  • Consider limiting them to lower-risk channels or manual review before large-scale campaigns

That lets you:

• Flag numbers where consent is no longer valid
• Trigger re-permission flows, such as email outreach or manual contact attempts
• Remove or downgrade numbers from auto-dial campaigns

Action step

☐ For each prospect record with consent, pass the phone number and consent date through the Reassigned Numbers API. Tag any “YES” results as non-dialable. On the other hand, tag “NO” if the number has not been reassigned. Tag “NO_DATA” as a separate risk group so agents do not treat them the same way as clean “NO” results.

5. Validate line type, reachability, and basic phone data  

After you handle DNC and reassigned risk, you still need to confirm that the number works and understand what kind of number it is.

Searchbug’s Advanced Phone Validator gives you data such as:

• Line type, such as wireless, landline, or VoIP
• Line status, such as active or disconnected
• Carrier information
• Location details, including state and timezone

Line type is important for compliance and for planning. Wireless numbers are often subject to stricter rules. VoIP numbers can signal disposable or anonymous use, which may require extra care. Landline numbers may belong to home phones or office desks.

Line status is just as important. Calling a large batch of disconnected or failed numbers not only wastes agent time but also costs the company money. It can also signal poor data practices to carriers and increase the likelihood that your calls will be blocked or flagged as spam.

Action step

☐ Run your prospect list through Advanced Phone Validator. Remove or park disconnected numbers. Mark VoIP numbers and wireless numbers in your CRM so you can adjust scripts and dialing methods.

6. Use timezone and state data to set safe calling windows 

TCPA rules set a national window for telemarketing calls, generally 8 a.m. to 9 p.m. at the called party’s local time. However, there are 26 states with their own time restrictions or narrower windows. Some limit weekend or holiday calls. Several have “mini-TCPA” rules that apply state penalties on top of federal ones.

If your team calls across states, guessing time zones based on area code is not enough. People carry numbers when they move.

Searchbug’s Advanced Phone Validator includes the timezone and state for each number. You can use this to:

• Build campaign rules around local time instead of area code
• Avoid late-night or early-morning calls that trigger complaints
• Respect state rules for weekend and holiday calling
• Route leads to agents who work the right hours for each region

Action step

☐ Create dialer rules that use timezone and state from your validator results. Do not allow agents to “override” time windows because a lead looks interesting.

7. Create risk segments and dialing rules  

After DNC checks, reassigned checks, and validation, your list will have different risk levels. Do not treat every number the same.

You might set up segments such as:

• Low risk
  • No DNC hits
  • No reassigned issues
  • Clear consent for calls or texts

• Medium risk
  • No DNC hits
  • No reassigned issues
  • Inquiry only or unclear consent

• High risk
  • Any DNC, complainer, litigator, or reassigned hit

Then set dialing rules for each group.

• Low risk can be used in auto-dial campaigns that match your legal team’s guidance.
• Medium risk may be manual dial only or limited to certain call types.
• High-risk cases should be excluded from calling or handled only with a separate legal review.

Action step

☐ Document these rules together with your compliance officer or outside counsel. Put the rules into your dialer and CRM so they are enforced through systems, not just “best effort” training.

8. Refresh consent flows and disclosures for next year  

Year-end is a good time to review how you collect consent for new leads. Courts and the FCC continue to refine what constitutes valid consent and a valid opt-out.

Work with your legal team to review:

• Lead vendor contracts
• Website and landing page forms
• Checkbox and disclosure language
• SMS opt-out instructions

Check that your process matches current rules, including the newer “any reasonable opt-out” guidance for text messages. Then make sure your CRM actually records when and how each person gave consent.

Action step

☐ Before January campaigns start, test leads through every entry point and confirm that consent data lands in your main system and is visible to the people who set up campaigns.

9. Train agents and QA on what the new list fields mean  

A strong checklist on paper does not protect you if agents ignore it. Your team needs to understand why new fields and tags exist and how they affect daily work.

Cover topics such as:

• What “do not call” means inside your organization
• How to read DNC, litigator, and reassigned flags inside the dialer
• When an agent must immediately honor an opt-out request
• How to log complaints or odd responses in a consistent way

Your QA team should also update scorecards. A call placed outside allowed hours or to a number that shows DNC or litigator flags is a serious issue, not a minor script error.

Action step

☐ Hold short training sessions before the year’s first campaigns. Record them for future hires. Attach the checklist to your training material so it stays part of daily practice.

10. Automate ongoing TCPA Compliance checks with APIs instead of one-time projects  

One year-end scrub is helpful. The real protection comes when checks run all year without extra effort from your team.

Searchbug supports this with APIs that you can connect to your CRM, dialer, or lead platform. For ongoing compliance, you can:

• Call the DNC Check API when new leads enter your system or before each campaign
• Call the Reassigned Numbers API when you refresh consent or before large SMS pushes
• Call the Advanced Phone Validator API when you import new lists or sync data from partners

You still keep your year-end checklist. The difference is that much of the heavy lifting happens in the background every day, not just in December.

Action step

☐ Talk with your technical team or vendor about where to plug in these APIs. Focus on points where large volumes of leads enter the system or where consent dates change.

☐ Look for a reliable TCPA Compliance tools API provider that offers free testing to validate results before scaling volume.

☐ If you use Zoho CRM, install and integrate Searchbug’s Phone Validator tool for Zoho CRM users to scrub phone numbers without leaving the CRM

How Searchbug fits into your year-end TCPA Compliance Checklist  

Searchbug is built for teams that want better data and lower TCPA risk without adding a full compliance department. The tools covered in this checklist work together.

• DNC Check provides a four-point screen against the National DNC, state DNC lists, known DNC complainers, and TCPA litigators.
• The Reassigned Numbers API shows when a number changed owners, so you can stop relying on old consent.
• Advanced Phone Validator confirms line type and status, and provides the state and timezone for safer dialing windows.

You can use these services as bulk uploads for one-time year-end cleanup or as APIs that sit behind your lead flow and run checks all year.

TCPA penalties can reach hundreds of dollars per call and thousands when you add willful findings and class action math.

Year-end list work is one of the few projects that directly lowers that risk while also improving connect rates and agent productivity.

If you want to make next year’s outbound campaigns safer and more effective, start with your data. Audit your list. Run the checks. Lock in better rules. Then give your agents the clear, clean records they need to make calls with confidence.

To help you gear up for the new year, we invite you to register for a FREE API Test Account of Searchbug to try our TCPA Compliance APIs for free!