Article
TCPA Established Business Relationship (EBR) Rules
enzodialer.com
Quoted on this wiki
Every place a page here uses this source, in the order the words come in it.
Where Enzo Fits — and Where It Doesn’t “The dialer itself is compliant tooling; whether your calling is lawful depends on your lists, records, and behavior.” Run the EBR as arithmetic: 18 months from a purchase, 3 months from an inquiry, dead on a single stop request, and never a substitute for written consent. Keep the dates in your records and the exemption does what it was designed to do — let you call your own customers without a registry violation.
In Compliance
What Counts as an Established Business Relationship “The definition at 47 C.F.R. § 64.1200(f)(5) turns on two clocks, both measured backward from the moment you dial:” Trigger Window Cite Purchase or transaction with your company 18 months immediately preceding the call 47 C.F.R. § 64.1200(f)(5) Inquiry or application regarding your products or services 3 months immediately preceding the call 47 C.F.R. § 64.1200(f)(5) Company-specific do-not-call request Terminates the EBR immediately, regardless of either window 47 C.F.R. § 64.1200(f)(5)
The definition at 47 C.F.R. § 64.1200(f)(5) turns on two clocks, both measured backward from the moment you dial: “Purchase or transaction with your company 18 months immediately preceding the call” The windows run from the most recent qualifying event — a repeat purchase restarts the 18-month clock. Nothing survives a company-specific do-not-call request: one “take me off your list” ends the relationship on the spot, even from a customer who bought yesterday.
The definition at 47 C.F.R. § 64.1200(f)(5) turns on two clocks, both measured backward from the moment you dial: “Inquiry or application regarding your products or services 3 months immediately preceding the call” The windows run from the most recent qualifying event — a repeat purchase restarts the 18-month clock. Nothing survives a company-specific do-not-call request: one “take me off your list” ends the relationship on the spot, even from a customer who bought yesterday.
Trigger Window Cite Purchase or transaction with your company 18 months immediately preceding the call 47 C.F.R. § 64.1200(f)(5) Inquiry or application regarding your products or services 3 months immediately preceding the call 47 C.F.R. § 64.1200(f)(5) Company-specific do-not-call request Terminates the EBR immediately, regardless of either window 47 C.F.R. § 64.1200(f)(5) “The windows run from the most recent qualifying event — a repeat purchase restarts the 18-month clock.” An “Existing Relationship” Is Not the Legal Test
The definition at 47 C.F.R. § 64.1200(f)(5) turns on two clocks, both measured backward from the moment you dial: “Company-specific do-not-call request Terminates the EBR immediately, regardless of either window” The windows run from the most recent qualifying event — a repeat purchase restarts the 18-month clock. Nothing survives a company-specific do-not-call request: one “take me off your list” ends the relationship on the spot, even from a customer who bought yesterday.
The Established Business Relationship: What Calling Your Own Customers Actually Exempts “That is the entire exemption: it unlocks the national DNC rules and nothing else — not consent, not extended hours — and it dies the moment the person says stop.” This page is education, not legal advice. A dialer is a tool — compliance depends on how you use it. Enzo does not scrub lists against the national or state DNC registries — run every list through a third-party scrubbing service before uploading it. Enzo provides campaign-level internal DNC (per-campaign only). Consult a TCPA attorney for your specific situation.
State Laws: Don’t Assume the Federal EBR Carries Over “A growing list of states have their own mini-TCPA or telemarketing statutes — Florida’s Telephone Solicitation Act, Oklahoma’s Telephone Solicitation Act, Texas SB 140, Washington’s Robocall Scam Protection Act, and Maryland’s Stop the Spam Calls Act among them — each with its own consent, hours, frequency, and exemption rules.” Where Enzo Fits — and Where It Doesn’t