Washington, DC – The U.S. Federal Communications Commission (FCC) is developing a new federal do-not-call (DNC) registry – and unlike the original telemarketing DNC Registry, this one would restrict telephone survey research.

Implementing a new U.S. law, the FCC is planning a new DNC registry limited to public safety answering point (PSAP) numbers. The PSAP registry builds upon the existing legal requirements in the Telephone Consumer Protection Act (TCPA), which forbids using any form of automated dialing to call "any emergency telephone line (including any “911” line and any emergency line of a hospital, medical physician or service office, health care facility, poison control center, or fire protection or law enforcement agency)."

Compliance with that existing law has always been challenging and unreliable, according to the Marketing Research Association (MRA), which filed comments with the FCC today.

MRA’s Director of Government Affairs Howard Fienberg, PLC, explained that, “Since there is no reliable listing of emergency lines, the PSAP registry could help prevent researchers from inadvertently calling emergency lines with their autodialers and violating the law. We support the new registry and will work with the FCC to make it functional, efficient and affordable.”

Telephone survey research expert Linda Piekarski of Survey Sampling International (SSI) provided much of the technical background for MRA’s comments. As she explained, “Since we are not telemarketers, the FCC needs to model this registry after the NeuStar list of ported cell phone numbers instead of trying to shoehorn it into the telemarketing DNC model. The NeuStar list has all the appropriate safeguards to protect emergency lines while making survey research compliance more efficient and reliable.”

MRA also answered some specific legal questions raised by the FCC, advocating for a “citation first” model of enforcement, in order to protect researchers against accidents, errors and unintended actions, and supporting a proposed FCC “safe harbor… for operators of automatic dialing equipment who can demonstrate that any prohibited call to or disclosure of the registered numbers is the result of an error despite routine business practices designed to ensure compliance.”

In addition to uncertainties in how the FCC will implement the new registry, it remains to be seen how often autodialer users will need to access the registry and scrub their calling lists. MRA will help the FCC iron out such details as the regulatory process moves forward.

(Also, see MRA's comments on the FCC website.)


Founded in 1957, the Marketing Research Association (MRA) is the leading and largest association of the survey, opinion and marketing research profession in the U.S., which delivers insights and intelligence to guide the decisions of companies providing products and services to consumers and businesses. Learn more at http://www.insightsassocation.org