Internal do not call list

An internal do not call list is the list a firm keeps of people who told that firm to stop calling. It is separate from the federal registry and it is not downloaded from anyone. It is assembled out of what consumers said on your own calls, it binds the entity that was asked, and under the FCC rule it has to exist before the first telemarketing call goes out rather than after the first complaint arrives.

Six minimum standards stand in front of the first dial

47 CFR 64.1200(d) opens by forbidding telemarketing calls to a residential subscriber unless the caller has already instituted procedures for maintaining such a list, then sets six minimum standards those procedures must meet: a written policy available upon demand, personnel informed and trained in the existence and use of the list, recording of requests, identification of callers, a default rule about affiliates, and a period the request survives. The order matters less than the word instituted.

What the caller has to say, and what has to happen at the moment of asking

Under 64.1200(d)(3) the request is recorded and the name, if provided, and the telephone number go on the list at the time the request is made, and the request is honored within a reasonable time, never more than ten business days from receipt. Under 64.1200(d)(4) the caller gives the name of the individual caller, the name of the entity on whose behalf the call is made, and a telephone number or address, which may not be a 900 number.

That ten business day ceiling belongs to the company-specific list. An identically worded ceiling sits in 64.1200(a)(10) for revocation of consent, which is a separate rule about a separate act and is covered in revocation of consent. One request, asked of one firm, can trigger both.

The FTC writes the same duty as a prohibition

16 CFR 310.4(b)(1)(iii)(A) makes it an abusive practice to call a person who previously has stated that he or she does not wish to receive calls made by or on behalf of that seller. The paragraph before it bans obstructing the request: hanging up, charging a fee for honoring it, requiring the person to sit through a sales pitch first, requiring a call to a different number, or requiring the person to name the seller. A list is how a firm proves it complied.

Source: 47 CFR 64.1200(d), lead-in and standards (1) through (6), and 16 CFR 310.4(b)(1)(ii), (b)(1)(iii)(A), (b)(2) and (b)(3)(iii), both read in full on 20 September 2026 through the eCFR renderer API, which returns the regulation text where direct eCFR pages redirect to an access interstitial. 47 CFR 64.1200(d)(6) was read a second time in the GPO annual CFR XML at govinfo.gov and returned the identical sentence. These texts support the standards, the recording duty, the ten business day ceiling in (d)(3), the caller identification items in (d)(4) and the FTC prohibitions above. They do not support any statement about how many firms maintain such a list or how often one fails, and no such statement appears here.

One rule gives a number, the other gives none

The FCC is explicit. 64.1200(d)(6) says a do-not-call request must be honored for 5 years from the time the request is made. The FTC prohibition attaches no period at all. It describes a person who previously has stated a wish not to be called, and the sentence ends. So five years is the answer to one rule and not to the other, and a firm reading only the FCC number has read the half of federal law that happens to contain a deadline.

Why a bought record cannot answer this question for you

A request made to your branch was made to your branch. 64.1200(d)(5) applies it to the particular entity that called, not to affiliates unless the consumer reasonably would expect them included, and 64.1200(d)(3) requires prior express permission before it is shared or forwarded onward. The FTC bans trading in these lists outright at 310.4(b)(2). Nothing about that duty arrives inside a lead file, and nothing in a lead file discharges it.

Two consequences follow for a desk. 64.1200(d)(3) places liability on the entity on whose behalf the call is made even where another party records or maintains the requests, so outsourcing the record does not outsource the exposure. And 64.1200(f)(5)(i) provides that a seller-specific do-not-call request terminates an established business relationship even if the consumer keeps doing business with the seller, which removes the exception a desk is most likely to be relying on.

Where this sits next to the registry and the defence

The federal file and this list answer different questions. Who is on the national list, and why a purchased record so often is, belongs to the National Do Not Call Registry. What a firm can raise after the wrong number has already been dialled belongs to do not call safe harbor, whose conditions count a maintained list as one item among several. This page is the list itself.

One figure is missing on purpose. Neither agency publishes how many sellers actually maintain these procedures, how many requests are recorded, or which of the six standards fails most often. The rules state duties and stop; they report no outcomes, and numbers of that kind in circulation trace to commentary rather than to a document anyone can open. None is printed here.

Source: 47 CFR 64.1200(d)(3), (d)(5), (d)(6) and (f)(5)(i), and 16 CFR 310.4(b)(2), regulation text read 20 September 2026. They support the five year honoring period in the FCC rule, the absence of any period in 16 CFR 310.4(b)(1)(iii)(A), the default that a request reaches the calling entity and not its affiliates, the prior express permission needed before a request is shared or forwarded, the liability of the entity on whose behalf a call is made where a third party holds the record, the ban on selling, renting, leasing, purchasing or using such a list, and the termination of an established business relationship by a seller-specific request. The 540 day and eighteen month figures that circulate in this area belong to the two established business relationship definitions, 16 CFR 310.2(q)(1) and 47 CFR 64.1200(f)(5), not to this rule, and are not used here.