Compliance & Outreach Guidelines.

1What PropScored Is

PropScored is a lead generation platform for real estate professionals and investors. We source property data from public records, county filings, and licensed data providers — score it using a proprietary algorithm — and conduct automated outreach to property owners on your behalf, including email sequences and direct mail. When a property owner responds, that lead is delivered to you for direct follow-up. Subscribers also receive access to an AI-powered call list to initiate qualifying conversations with their prospects directly.

2Division of Responsibility

PropScored operates email sequences and direct mail on your behalf, in compliance with applicable law. PropScored also provides a subscriber AI call list — DNC-registered and known TCPA litigator records are automatically blocked from that list and cannot be dialed through the PropScored dashboard. You are solely responsible for ensuring any additional contact you initiate independently complies with applicable federal, state, and local law.

3Permitted Channels

Channel	Permitted For	Requirement
Email	Cold outreach to property owners	CAN-SPAM compliance (opt-out, accurate headers, physical address)
Direct Mail	Cold outreach to property owners	No restrictions — NCOA address validation recommended
Live Personal Calls	Cold outreach with DNC scrub	Human caller, non-ATDS only; DNC-registered numbers must be suppressed
Any channel	Consented leads (form submitted with written consent)	Prior express written consent on file

4Prohibited Channels

5Live Personal Calls

Live calls made by a human from a regular phone (no prerecorded voice, no automatic telephone dialing system) are not subject to TCPA § 227(b). They are the most legally defensible voice channel for cold property owner outreach.

The DNC Registry and the Purchase Offer Defense

TCPA § 227(c) prohibits "telephone solicitations" to numbers on the National Do Not Call Registry. Whether a call is a "solicitation" depends on framing. Federal courts (Coffey v. Fast Easy Offer, D. Ariz. 2025; Aussieker v. Aghazadeh, E.D. Cal. 2025) have held that calls offering to buy a property are not "telephone solicitations" — because the statute requires encouraging a purchase by the consumer, not from the consumer.

Listing Agent vs. Buyer Representative

Call Type	Example Pitch	DNC Defense?
Buyer's representative / direct purchase offer	"I want to purchase your property"	Yes — Coffey defense applies
Listing agent / representation pitch	"I'd like to help you sell / list your property"	No — service solicitation; DNC scrub required

PropScored data includes DNC flags from licensed skip trace providers. Agents pitching listing representation must suppress DNC-flagged numbers before dialing. When using the PropScored AI call list, DNC-registered records are automatically blocked at the system level — they do not appear in the call list and cannot be dialed through the dashboard. Investors making pure purchase offer calls may rely on the Coffey defense — see Section 11.

PropScored AI Call List

PropScored's subscriber dashboard includes a call list where agents manually initiate outbound calls via our AI voice system. Each call is triggered individually — the agent clicks a button for one prospect at a time. The AI conducts the qualifying conversation.

DNC and litigator protection: PropScored automatically suppresses DNC-registered numbers and records flagged as known TCPA litigators from the call list. These records cannot be dialed through the PropScored dashboard.

Note: The legal classification of AI-voice calls is evolving. The FCC has addressed AI voice in the context of automated dialing systems (Feb 2024 Declaratory Ruling). Because PropScored calls are manually triggered one at a time — not auto-dialed — the ATDS component of TCPA § 227(b) is not implicated. Clients making calls through PropScored's system should consult a qualified TCPA attorney if they have questions about the AI voice component in their specific state.

Requirements for Live Calls (Independent of PropScored)

1. Human caller only — no predictive dialer, no ATDS
2. DNC scrub — if dialing outside of the PropScored call list, suppress DNC-flagged numbers before dialing
3. No bundled services pitch — if the call includes a listing services offer, the Coffey defense does not apply
4. Calling hours — 8 AM–9 PM in the recipient's local time zone (federal minimum; some states are tighter)
5. Identify yourself — state your name and the purpose of the call within the first 30 seconds

6DNC Registry Compliance

PropScored-delivered leads include a DNC flag sourced from licensed skip trace providers. This flag indicates whether the associated phone number appears on the National Do Not Call Registry at the time of skip trace.

PropScored's AI call list automatically blocks DNC-registered records and known TCPA litigators. These records are suppressed at the system level and cannot be dialed through the dashboard. This protection applies only to calls made via PropScored's call list — it does not extend to any outreach you initiate independently.

For any independent outreach you conduct, you are responsible for:

• Suppressing DNC-flagged numbers before any automated or solicitation-based outreach
• Maintaining your own internal do-not-contact list and honoring opt-out requests within 30 days
• Re-scrubbing phone numbers against the DNC registry before outreach if more than 31 days have passed since the data was exported

PropScored does not guarantee the real-time accuracy of DNC flags — registry data changes daily and the DNC flag in delivered data represents a point-in-time snapshot.

7State Risk Tiers

Several states have enacted "mini-TCPA" laws that add compliance requirements beyond federal law. These apply primarily to automated outreach (RVM, SMS, predictive dialers) — live human calls are generally not subject to these state statutes.

Risk Level	States	Key Statute	What it Adds
AVOID (explicit RVM/voicemail statutes)	FL, GA, CT	FL § 501.059; GA SB 73; CT SB 1058	FL: explicit "voicemail transmission" ban for solicitations. GA: unlimited damages, vicarious liability, strict liability (eff. July 2024). CT: $20,000/violation.
High (mini-TCPA + elevated damages)	TX, WA, OK, MD, MA, IL, OR, CA, NY	Various	State written-consent requirements + per-violation damages above $1,500 federal floor
Elevated	UT, MN, WI, NJ, TN, VA	Various	Prior written consent + state enforcement
Moderate	MO, IN, AL, CO, KY, RI	State DNC	Additional DNC registry scrubbing required
Federal standard	All remaining states	TCPA only	Federal TCPA is the applicable floor

8Data Use & Liability Limitation

PropScored conducts automated outreach to property owners on behalf of clients — including email sequences and direct mail. PropScored also provides an AI-powered call list through which clients initiate qualifying calls manually, one prospect at a time. This outreach is performed at the client's direction and for the client's benefit. Once outreach has been completed and leads have been delivered, PropScored's responsibility ends. PropScored does not supervise, control, or have any involvement in client-initiated follow-up communications beyond the PropScored platform.

What PropScored Is Not Responsible For

PropScored is not responsible for:

• Any outreach conducted by the client or the client's agents using delivered data
• Client violations of TCPA, CAN-SPAM, DNC regulations, or state telemarketing laws
• Outcomes of client calls, emails, texts, or mail sent to property owners
• Accuracy of phone numbers, email addresses, or mailing addresses after the date of delivery
• Changes to DNC registry status after the data export date

Indemnification

By using PropScored's platform and receiving lead data, the client agrees to indemnify, defend, and hold harmless PropScored, its officers, directors, employees, contractors, and agents from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising from: (a) outreach conducted by PropScored on the client's behalf; (b) the client's use of delivered lead data; (c) any outreach, communication, or contact the client independently initiates with property owners; or (d) the client's violation of any applicable law or regulation.

Data Sourcing

PropScored sources property data from licensed data aggregators of public county records, court-filed foreclosure notices, and licensed MLS data feeds. All data sources are used in compliance with their respective terms of service. PropScored does not scrape, harvest, or access data through unauthorized means.

9Client Acknowledgment

By signing up for PropScored and accessing lead data, the client confirms that they:

• Have read and understood these compliance guidelines
• Authorize PropScored to conduct outreach on their behalf and agree to indemnify PropScored for any claims arising from that outreach
• Accept sole responsibility for all independent outreach they initiate using PropScored-delivered data
• Will comply with TCPA, CAN-SPAM, the National DNC Registry, and all applicable state telemarketing laws
• Will not use PropScored data for any purpose that violates applicable law
• Understand that PropScored is a data provider and not a licensed attorney; nothing in these guidelines constitutes legal advice

10No Legal Advice

Questions about these guidelines: stephen@propscored.com

11Investor-Specific Rules Investor Only

Investors using PropScored to source motivated seller leads operate under a materially different legal framework than listing agents for one critical channel: live personal calls. This section summarizes all investor-specific rules in one place.

The Purchase Offer Defense — Live Calls to DNC Numbers Are Permitted

TCPA § 227(c) prohibits "telephone solicitations" to numbers on the National Do Not Call Registry. The statute defines a solicitation as a call encouraging the purchase, rental, or investment in property, goods, or services by the person called. When an investor calls to make a purchase offer — offering to buy the property owner's home — the call encourages a purchase from the consumer, not by the consumer. Federal courts have held this falls outside the solicitation definition.

What the Defense Covers — and What It Does Not

Channel	Agents	Investors	Notes
Live call — non-DNC number	✓	✓	Human caller, no ATDS, 8am–9pm local
Live call — DNC-registered number	✗ (solicitation)	✓ (purchase offer)	Coffey defense applies; must be a pure purchase offer pitch
RVM / ringless voicemail	✗	✗	§ 227(b) — requires consent regardless of pitch type
Automated SMS / text	✗	✗	§ 227(b) — requires consent regardless of pitch type
ATDS / predictive dialer	✗	✗	§ 227(b) — requires consent regardless of pitch type
Email (cold)	✓	✓	CAN-SPAM compliance required
Direct mail	✓	✓	No restrictions

What Disqualifies the Defense

Requirements for Investor Live Calls

1. Human caller only — no ATDS, no prerecorded voice, no predictive dialer
2. Pure purchase offer pitch — do not bundle any services into the call script
3. Calling hours — 8 AM–9 PM in the recipient's local time zone
4. Identify yourself — state your name and that you're interested in purchasing the property
5. Honor opt-outs — if the property owner asks not to be called again, add to your internal DNC list immediately
6. State law still applies to automated channels — mini-TCPA statutes in FL, GA, TX, and others still govern any RVM or SMS regardless of investment framing