DNC scrubbing: what it is and what it checks

1. What a DNC scrub is

The National Do Not Call Registry is a federal list of phone numbers whose subscribers have said they do not want telephone solicitations. The FCC rule at 47 CFR 64.1200(c)(2) says no person or entity shall initiate any telephone solicitation to a residential telephone subscriber who has registered their number on the national do-not-call registry, and that registrations must be honored indefinitely, or until the registration is cancelled by the consumer or the number is removed by the database administrator.

A scrub is the check you run to apply that rule to a list: each number is compared with the registry, and registered numbers are flagged or removed before anyone dials. A complete scrub also compares the list with your own internal do-not-call list, the record of people who asked you directly not to call.

2. What the FCC rule says about the scrub itself

47 CFR 64.1200(c)(2) says a person or entity that made a telephone solicitation to a registered number will not be liable for violating that requirement if it can show the violation was the result of error and that, as part of its routine business practice, it met these standards:

• (A) It has established and implemented written procedures to comply with the national do-not-call rules.
• (B) It has trained its personnel, and any entity assisting in its compliance, in procedures established pursuant to the national do-not-call rules.
• (C) It has maintained and recorded a list of telephone numbers that the seller may not contact.
• (D) It uses a process to prevent telephone solicitations to any telephone number on any list established pursuant to the do-not-call rules, employing a version of the national do-not-call registry obtained from the administrator of the registry no more than 31 days prior to the date any call is made, and maintains records documenting this process.
• (E) It uses a process to ensure that it does not sell, rent, lease, purchase or use the national do-not-call database, or any part of it, for any purpose except compliance with this section and any such state or federal law to prevent telephone solicitations to telephone numbers registered on the national database.

So the rule ties the scrub to timing (31 days), to records (documenting the process), and to an internal list. A one-time scrub of an old file does not meet item (D) for calls made months later.

3. What a scrub does not settle

A registry check answers one question: is this number registered? It does not answer others that can apply to the same call:

• Calling hours. 47 CFR 64.1200(c)(1) bars telephone solicitations before 8 a.m. or after 9 p.m. local time at the called party’s location.
• Internal do-not-call requests. A person who told you to stop calling stays on your own list whether or not they are on the national registry.
• Autodialers, prerecorded voice and texts. Separate parts of 47 U.S.C. 227 and 47 CFR 64.1200(a) cover these.
• State rules. This page does not review state do-not-call lists. The skip tracing laws guide says those statutes were not verified. Check the state where the person is.
• Who the person is. A clean number can still belong to someone other than the owner you meant to reach. See what a skip trace match proves.

The skip tracing laws guide covers these rules together.

4. Why the check matters

47 U.S.C. 227(c)(5) gives a person who received more than one telephone call within any 12-month period by or on behalf of the same entity, in violation of the do-not-call regulations, a private right of action for actual monetary loss or up to $500 for each violation, whichever is greater. A court may increase the award to not more than three times the amount available if it finds the violation was willful or knowing. The same subsection gives an affirmative defense if the defendant shows it had established and implemented, with due care, reasonable practices and procedures to prevent such calls. That is why the scrub, its date and its records matter together.

5. How to run a scrub on a skip traced list

1. Keep every phone number in its own column with its own status, so a flag stays with its number.
2. Compare the numbers with a registry version obtained no more than 31 days before your calls, and with your internal do-not-call list.
3. Record the date of the check and the result for each number.
4. Recheck before a later campaign if the 31-day window has passed.
5. Keep calling hours, consent and state rules as separate checks.

Sellers and telemarketers get registry access through the FTC. The FTC’s Q&A for telemarketers and sellers explains who must pay for access and how it works.

6. What Locate Next does here

What Locate Next says on its own pages, word for word: “Check each number’s Do Not Call status before outreach. A status does not decide what contact is allowed.” On the security and data sources page: “US-number checks in Export are planned for launch, subject to provider access. Unanswered numbers stay Not checked.” And: “Our DNC check flags listed numbers; it doesn’t decide whether a call or text is allowed.” On the CRM export page: “A DNC flag from your file stays with its number through sorting and filtering. A number your file flagged never shows as clear.”

Common questions

Sources

1. 47 CFR 64.1200, FCC telemarketing and do-not-call rules. Checked October 22, 2026.
2. 47 U.S.C. 227, Telephone Consumer Protection Act. Checked October 22, 2026.
3. FTC, Q&A for telemarketers and sellers about the Do Not Call provisions of the TSR. Checked October 22, 2026.
4. 16 CFR Part 310, Telemarketing Sales Rule. Checked October 22, 2026.

This page is general information, not legal advice.