{"id":325,"date":"2026-09-14T02:57:39","date_gmt":"2026-09-14T07:57:39","guid":{"rendered":"https:\/\/realdialer.com\/real-estate-team-calling-policy\/"},"modified":"2026-09-14T02:57:39","modified_gmt":"2026-09-14T07:57:39","slug":"real-estate-team-calling-policy","status":"publish","type":"post","link":"https:\/\/realdialer.com\/real-estate-team-calling-policy\/","title":{"rendered":"A Written Calling Policy for a Real Estate Team"},"content":{"rendered":"

A calling policy is the written document that says how a team makes outbound calls lawfully: who may call, from what lists, in what hours, with what checks before the dial, what happens when someone says stop, what is recorded, and who checks that all of it is being done. It is short. It is signed. The owner signs it and so does every person who dials. And it exists before anyone asks for it, which matters, because the federal rule that governs telemarketing calls assumes it does. 47 CFR 64.1200(d)(1)<\/a> requires that anyone making calls for telemarketing purposes “must have a written policy, available upon demand, for maintaining a do-not-call list.” The FTC’s parallel rule, at 16 CFR 310.4(b)(3)<\/a>, makes “established and implemented written procedures” the first element of the safe harbor that protects a caller from liability for a mistaken call.<\/p>\n

Most real estate teams do not have one. They have a dialer with settings, a script, a vague understanding that the list was scrubbed, and a team lead who believes that compliance is something the vendor does. The do-not-call rules<\/a> piece lays out the rules themselves and the safe harbor as a checklist. This is about the document that checklist assumes, and it is aimed at the team lead, because NAR’s April 2024 note<\/a> on telemarketing suits makes the point that brokerages, not only agents, get named when an agent’s calls go wrong, and its recommendation is a formal policy and regular training.<\/p>\n

Why a document and not a habit<\/h2>\n

The safe harbor in both rules protects a caller who reaches a registered number by mistake. Its first element is written procedures. Its second is that personnel were trained in them. Its last, in the FTC version, is that the caller monitors and enforces compliance with the procedures established. Each of those is a thing the team has to be able to show, after the fact, to someone who is not inclined to take their word for it. A habit cannot be shown. A document can. One with a date, a signature page and a training log is the difference between a mistaken call that is forgiven and one that is not.<\/p>\n

The policy also settles arguments before they start. A new agent who wants to call at 8:15 in the evening because a lead texted, an ISA who wants to keep a number the homeowner asked to be removed from “just for texts,” a team member who imports a list from a previous brokerage: each is a decision, and a team without a policy makes it fresh every time, differently, depending on who is in the room.<\/p>\n

The nine sections<\/h2>\n

A team’s policy needs nine sections, and none of them is long. The retention piece<\/a> covers the records; the sections below say what the policy states about each area and what it leaves behind as evidence.<\/p>\n

\n\n\n\n\n\n\n\n\n\n\n\n\n\n
Section<\/th>\nWhat it states<\/th>\nWhich rule it answers<\/th>\nThe evidence it leaves<\/th>\n<\/tr>\n<\/thead>\n
1. Scope and owner<\/td>\nWho the policy covers, including ISAs and vendors calling on the team’s behalf; the named owner; the review date<\/td>\n64.1200(d)(1); TSR 310.4(b)(3)(i)<\/td>\nThe signed document with a date<\/td>\n<\/tr>\n
2. Lists and scrubbing<\/td>\nWhere numbers may come from; the registry scrub against a version no older than 31 days; the state lists; who runs the scrub and when<\/td>\n64.1200(c)(2)(i)(D); TSR 310.4(b)(3)(iv)<\/td>\nThe scrub log: date, registry version, list name, count removed<\/td>\n<\/tr>\n
3. The internal do-not-call list<\/td>\nThat a stop request from anyone is recorded at once, applies company-wide, and is honored within ten business days and kept five years<\/td>\n64.1200(d)(3), (d)(6)<\/td>\nThe internal list with dates and the source of each request<\/td>\n<\/tr>\n
4. Calling hours<\/td>\nThe federal window and the tighter state windows for the states the team calls, in the called party’s time zone; who sets the dialer<\/td>\nTSR 310.4(c); the state windows<\/a><\/td>\nDialer settings screenshot, dated; the state list<\/td>\n<\/tr>\n
5. Identification<\/td>\nThat every call gives the caller’s name, the brokerage, and a callback number; the caller ID rules<\/td>\n64.1200(d)(4); the caller ID rules<\/a><\/td>\nThe script header; the number registration record<\/td>\n<\/tr>\n
6. Consent and texting<\/td>\nWhat counts as consent for a call or text, how it is captured, and where the record lives<\/td>\nThe DNC rules<\/a> and the texting rules<\/a><\/td>\nThe consent record per number<\/td>\n<\/tr>\n
7. Recording<\/td>\nWhether calls are recorded, the consent rule applied by state, and who may listen<\/td>\nThe recording consent<\/a> rules<\/td>\nThe recording consent line; the access list<\/td>\n<\/tr>\n
8. Training<\/td>\nThat every caller reads and signs the policy before the first dial and annually after; what the training covers<\/td>\n64.1200(d)(2); TSR 310.4(b)(3)(ii)<\/td>\nThe training log with names and dates<\/td>\n<\/tr>\n
9. Monitoring and complaints<\/td>\nWho spot-checks what, how often; what happens when a complaint arrives; the discipline for a breach<\/td>\nTSR 310.4(b)(3)(v); the complaint response<\/a><\/td>\nThe spot-check log; the complaint file<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n

The owner<\/h2>\n

A policy without a named owner is a policy nobody reads. The owner is the team lead or, on a larger team, the operations person, and the name is in section one. The owner runs the annual review, keeps the training log, receives complaints, and is the person who can produce the document on demand, which under 64.1200(d)(1) is the whole test. When the owner changes, the policy is re-signed. When the rules change, and both the retention period and the window for honoring a stop request changed in recent rulemakings, the owner updates the section and the date, and the old version is kept, because a complaint about a call made in March is judged against the policy in force in March.<\/p>\n

The owner is also the person who decides the question every team eventually faces: whether the ISA or the vendor calling on the team’s behalf is covered. They are. Both rules reach anyone calling on behalf of the seller, and section one says so, and the training log has their signatures too.<\/p>\n

Training, which is the second element<\/h2>\n

Training is a section of the policy and a separate obligation, and the two rules agree on it. 64.1200(d)(2) requires that personnel engaged in any aspect of telemarketing be “informed and trained in the existence and use of the do-not-call list.” The TSR safe harbor requires that the caller “trained its personnel, and any entity assisting in its compliance, in the procedures.” On a real estate team that means: the new agent reads the policy before the first dial, not during the first two weeks<\/a> as an afterthought; the reading is signed and dated; the internal do-not-call procedure is demonstrated on the actual system, so the agent knows which button records a stop request and what it does; and the whole thing is repeated once a year, with the log updated.<\/p>\n

The training log is the evidence. A team that trained everyone and wrote nothing down has, for safe harbor purposes, trained no one.<\/p>\n

Monitoring, which is the last<\/h2>\n

The FTC’s safe harbor ends with monitoring and enforcement, and this is the element most teams skip because it sounds like surveillance. It is smaller than that. Once a month, the owner pulls a sample of calls and checks four things against the policy: the number was on a scrubbed list, the call was inside the window for the called party’s state, the identification was given, and any stop request in the recording made it to the internal list. The coaching piece<\/a> already has the team listening to recordings for skill; the compliance check rides on the same recordings and takes twenty minutes. The check is logged, with the date and what was found, and a breach is handled the way section nine says, which is written down before anyone breaches anything, so that it is a rule and not a reaction.<\/p>\n

Three things the policy is not<\/h2>\n

Not the script.<\/strong> The script says what an agent says. The policy says what an agent may do. The script header carries the identification the policy requires, and that is the whole overlap. A team that puts the policy inside the script book has hidden it.<\/p>\n

Not the dialer’s settings.<\/strong> The dialer enforces the hours and may run the scrub, and the policy says that it does and who checks that it did. A setting is not a procedure until the policy names it, dates it, and assigns someone to verify it, because a setting can be changed by anyone with the password and the rule asks who was responsible.<\/p>\n

Not a guarantee.<\/strong> The safe harbor forgives error. It does not forgive a pattern, and it does not reach a call made with consent that was never obtained or a text sent without it. The policy is the team’s best evidence that a mistake was a mistake. Nothing in it licenses another one.<\/p>\n

The day the document is read<\/h2>\n

Nobody reads a calling policy on a good day. It is read on the day a letter arrives, from a homeowner, a plaintiff’s firm or a state attorney general, asking about a call made eleven weeks ago to a number that turns out to have been registered. The complaint piece<\/a> describes that day. What the team can put on the table is the policy, dated before the call; the scrub log showing the list and the registry version; the training log with the agent’s signature; the internal list showing the number was not on it; and the spot-check log showing the team was looking. That is a mistaken call inside the safe harbor. Without the document, the same call is the same call, and the team has only its word.<\/p>\n

The teams hub<\/a> treats shared lists, shared records and shared standards as what makes a group of agents a team. The calling policy is the shortest of the standards and the one the rules assume. Write it in an afternoon, have counsel read it, sign it, train it, check it monthly, and put it where the owner can find it in five minutes, because that is exactly how long a person on the other end of a letter will give you.<\/p>\n","protected":false},"excerpt":{"rendered":"

The federal do-not-call rules assume a written policy exists and can be produced on demand, and the safe harbor that protects a team from a mistaken call starts with it. What the document is, the nine sections a real estate team’s version needs, who owns it, how it is trained and monitored, and the evidence each section produces when a complaint arrives.<\/p>\n","protected":false},"author":1,"featured_media":324,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_realdialer_meta_description":"The federal do-not-call rules assume a written policy exists and can be produced on demand, and the safe harbor that protects a team from a mistaken call starts with it. What the document is, the nine sections a real estate team's version needs, who owns it, how it is trained and monitored, and the evidence each section produces when a complaint arrives.","footnotes":""},"categories":[12],"tags":[],"class_list":["post-325","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-teams"],"_links":{"self":[{"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/posts\/325","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/comments?post=325"}],"version-history":[{"count":0,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/posts\/325\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/media\/324"}],"wp:attachment":[{"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/media?parent=325"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/categories?post=325"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/realdialer.com\/blog\/wp-json\/wp\/v2\/tags?post=325"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}