TCPA List Validation

TCPA (The Telephone Consumer Protection Act) List Validation helps you to follow the US market regulations and stay compliant when running SMS and MMS campaigns. It automatically excludes Litigators from your SMS/MMS marketing program. It helps you to avoid sending text messages to deactivated phone numbers. It also ensures you do not send marketing text messages to customers whose phone numbers were reassigned.

In this guide, you will learn more about:

  • how the TCPA List Validation module works,
  • how to configure it in Bloomreach Engagement,
  • what use cases it is beneficial for and much more.


The Telephone Consumer Protection Act (TCPA) is the primary federal law governing the regulation of telephone solicitations in the US market. Read more about TCPA and CTIA compliance in the US market.


It is required to assign at least one consent category within the TCPA List Validation settings to start using it.

What the Feature Does

TCPA List Validation consists of 2 separate parts:

  • Scrub against DNC List,
  • Check against the Reassigned phone numbers database.

Scrub against the DNC List

It helps you to scrub your database of phone numbers against the Do Not Call (DNC) registry to detect potential litigators infiltrated between your subscribers. Then it disallows them to receive your marketing text messages immediately after they were marked as Litigators.

The result of the TCPA check is stored as the tcpa_check_result customer attribute. If the scrub identifies the phone number as Litigator (tracked as tcpa_check_result=Litigator), such phone numbers will be immediately ignored during the execution of the SMS/MMS campaigns. Bloomreach Engagement will also automatically track this number as an invalid_contact event which prevents any further SMS/MMS campaign for this customer.


Checking Frequency

There are two types of the TCPA check that happen. The first check is done every 15 days and if you want to change its time period to do more checks, please contact your Account Manager. Please note that the requiered period is every 31 days by law.

The second check is done daily.

There might be other possible results for the TCPA scrub check than litigators. Engagement does not exclude these customers from SMS/MMS campaigns and it is up to you to decide if their consent was collected by TCPA and CTIA regulations and guidelines. Read more about prior express written consent. If yes, these customers can still receive the SMS/MMS campaigns. If not, our recommendation is to filter them out of the campaign.

Examples of different TCPA check results:

  • tcpa_check_result=National (USA) 2021-01-01
  • tcpa_check_result=National (USA) 2021-01-01;State (TX) 2022-01-01


Important notice

Keep in mind you can store up to 255 customer properties. After you reach the storage limit any tracking that contains new customer attributes will be discarded (including tcpa_check_result) which will lead to the malfunction of the TCPA List Validation check.

Example of the customer profile after the positive litigator identification:

Example of the invali_contact event tracked under customer profile:

Check against the Reassigned Numbers Database

It helps you to identify deactivated or swapped numbers that are automatically opted out of your SMS marketing program. It is usually done within 24 hours of deactivation.

It checks against the reassigned phone numbers database. If the check identifies such a number, the consent for a customer is rejected automatically. Consent rejection ensures that no further SMS/MMS campaigns are sent out to the customer. Please note that the customer can be contacted only after they subscribe to the SMS/MMS again. These checks run on a daily basis and check only US/CA numbers.

Each consent rejection (consent event with event attribute action=reject) also contains additional information about the number of deactivations or swaps (event attribute message=TCPA reassigned number database: The phone number was deactivated or message=TCPA reassigned number database: The phone number was swapped).

Example of the consent event tracked for a deactivated phone number:

Configuration Settings

TCPA List Validation is available as a separate account module. It is disabled by default and needs to be enabled by the CSM. Once the account module is enabled, you can configure the TCPA List Validation via theProject Settings > Campaigns > Channels > SMS/MMS.

Use Cases

  • Automatically remove reassigned/deactivated numbers, and litigators from your sending list to ensure TCPA compliance.
  • Segment the users who changed carriers (and therefore were removed by the TCPA check) and ask for their consent again to receive SMS/MMS communications to their new number.
  • Have your users’ consent & preferences updated in real time and exclude users who do not want to be contacted from your sending list.
  • Strengthen your brand’s bond with customers by respecting their preferences and favorite communication channels.