Run each placement file through the lookup before the first call: numbers a carrier deactivated recently, mobile or landline after porting, which numbers can take a text, known TCPA litigators, and the time zone where each number was issued. It checks the number, not the person: no names, no right-party verification, no skip tracing.
Built from fields in the lookup response. The litigator check costs 1 extra credit.
1B+requests served by our validation network
~32%of numbers we look up are landline or VoIP
~7%of landlines we check can take a text
~1.5%flagged as TCPA litigators when the scrub is on
Where collection calls go wrong
“Numbers go stale between placement and the first call.”
A number reassigned since the consumer gave it now reaches someone who never consented, and the reassigned-number safe harbor only covers the FCC's database. deactivationDate flags carrier deactivations from the last 45 days.
Autodialed or prerecorded calls to a cell phone need the called party's prior express consent. The live carrier dip says mobile or landline after porting.
Under Regulation F, every collection text needs a clear, simple way to opt out of further texts to that number. smsEligible marks numbers that can take a text; the landline SMS check covers landlines.
About 1.5% of the numbers we check come back flagged as TCPA litigators when the scrub is on.
Source: CheckThatPhone lookup data
litigatorlitigator_type
Pre-dial rules, field by field
What a collections team does with each result. These rules check the number, never who answers it.
If the response shows
Field
Do this
Deactivated by the carrier recently
deactivationDatereason
Don't dial. Route the account to your own skip-trace process.
Mobile
nanpType = mobiledipCarrierType
Cell-phone consent path: no autodialed or prerecorded calls without the consumer's prior express consent.
Landline
nanpType = landlinedipCarrierType
Dial. Ignore action: "unsubscribe", which only means it can't take a text.
Can take a text
smsEligibledipMessagingEnabled
Eligible for your text workflow. Every message needs a clear, simple opt-out.
Local time
timezonetzOffsetgeoSource
Call between 8 a.m. and 9 p.m. at the consumer's location. Prefer the location on the account; the area code's zone is only where the number was issued.
Known TCPA litigator
litigatorlitigator_type
Send to compliance review before any call or text.
Carrier differs from your records
dipCarrierdipOcndipPorted
Update the account record. dipPorted has no date, so it says the number moved, not when.
Where it fits in the collection cycle
Step 1
At placement
Upload the placement file as a CSV: deduplicated, up to 1,000,000 rows, each unique number billed once.
Step 2
Before each campaign
DialTextReviewDon't dial
Re-check the numbers you are about to dial or text, or call the API from your dialer list-loading job. Deactivation data refreshes daily.
Step 3
Monthly portfolio re-scrub
Catch new deactivations and carrier changes across open accounts. Deactivation entries expire after 45 days, so re-scrub at least monthly.
One lookup, read the way a collector reads it
A mobile that ported to a new carrier: the cell-phone consent path applies, the carrier on the account record needs updating, it can take a text, it is not a known litigator, and the area code puts it on Central time.
50,000 placements, with the litigator scrub$100/mo50,000 placements × 2 credits = 100,000 credits. 100K plan: $100 (100,000 included)
Same file, without the scrub$100/mo50,000 placements × 1 credit = 50,000 credits. 100K plan: $100 (100,000 included)
State DNC and complainer checks never add credits. The landline SMS check adds 1 credit per landline; mobiles are not charged.
What the lookup covers, and what's still on you
The lookup gives you
Mobile or landline from a live carrier dip, after porting
Carrier deactivations in the last 45 days
Which numbers can take a text (the landline check adds 1 credit per landline)
Known TCPA litigators (+1 credit)
The time zone of the number's area code, or of an IP you pass
Current carrier, OCN and ported flag
Still your job
Calling hours at the consumer's location: before 8 a.m. and after 9 p.m. is presumed inconvenient · 12 CFR 1006.6(b)(1)(i)
Call frequency, tracked per debt in your own system: more than seven calls in seven consecutive days is presumed to violate the rule · 12 CFR 1006.14(b)(2)
A clear, simple opt-out in every text or email · 12 CFR 1006.6(e)
Prior express consent before autodialed or prerecorded calls to a cell phone · 47 CFR 64.1200(a)(1)(iii)
Right-party verification and finding new numbers: we return no names and do no skip tracing
Not legal advice.
Coverage and limits
State DNC: covers 38 states plus DC, refreshed weekly. Numbers in CO, FL, IN, LA, MA, MS, MO, OK, PA, TN, TX and WY aren't checked, and dncStateChecked is left out for them, so "not checked" never reads as clear.
No National Do Not Call Registry check. Registry access for sellers comes from the FTC at telemarketing.donotcall.gov.
No subscriber names or owner details.
deactivationDate: data refreshed daily, with a 1 to 7 day lag, and entries expire after 45 days. It is not a reassigned-number check.
Canadian numbers are validated and carrier-dipped like US numbers, but the state DNC check is US-only and Canada's National DNCL isn't checked.
Questions collection teams ask
Does this make us Regulation F compliant?
No. The lookup checks numbers; Regulation F governs how you communicate. Call frequency, for example, is counted per debt in your own system: more than seven calls in seven consecutive days is presumed to violate the rule (12 CFR 1006.14(b)(2)). The CFPB's debt collection rule FAQs cover the rest. This is not legal advice.
Can it find new numbers for an account?
No. We return no subscriber names, we don't confirm that a number belongs to the consumer (no right-party verification), and we don't do skip tracing. A deactivated number is a signal to route the account to your own skip-trace process.
Does it detect reassigned numbers?
No. deactivationDate shows a carrier deactivation in the last 45 days, but a reactivated number shows no date whether it went back to the same subscriber or a new one. The reassigned-number safe harbor in 47 CFR 64.1200(m) only covers the FCC's Reassigned Numbers Database.
Which time zone should we use?
Regulation F's calling hours use local time at the consumer's location (12 CFR 1006.6(b)(1)(i)). timezone comes from an IP you pass, or else from the area code, which is where the number was issued, not necessarily where the consumer lives. Prefer the location on the account. When your information conflicts, the CFPB's FAQs say a time that is convenient in every possible location complies.
Can we text these numbers?
smsEligible is "true" for active mobiles and, with the landline SMS check (+1 credit per landline), for landlines that can take a text; about 7% of the landlines we check can. Every collection text needs a clear, simple opt-out (12 CFR 1006.6(e)).
We collect our own accounts in-house. Does Regulation F apply?
Regulation F applies to debt collectors as the Fair Debt Collection Practices Act defines them, so ask counsel whether that includes your team. The TCPA's consent rule for autodialed or prerecorded calls to cell phones applies to every caller (47 CFR 64.1200(a)(1)(iii)).