{
  "id": "OPS-108",
  "slug": "ops-108",
  "title": "A do-not-call request is recorded when it is made",
  "statement": "A do-not-call request must be recorded, with the name and number, at the time the request is made.",
  "rationale": "The obligation is about latency rather than storage: a request written up at the end of the week is a week in which the number can still be messaged, and the record then shows a delay nobody can explain. It is also the moment the identifying detail is available — the person is on the phone — and reconstructing a name from a number afterwards is exactly what does not happen.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "internal do-not-call write latency",
  "severity": "BLOCKING",
  "detectability": [
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Make the request recordable during the contact — a field the agent sets before ending the call, not a form filed later — and write the name and number together. Done when the record timestamp matches the contact timestamp.",
  "example": "Agent sets Do Not Call on the account during the call: name, number, request received 2026-03-04T11:02Z.",
  "notes": "A workflow inside the brand. What the user has to check is whether their process asks anybody to do this after the fact; batch entry at the end of a shift is common and it is what creates the latency this rule is about.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Does the record timestamp on a do-not-call request match the contact timestamp?",
    "howToCheck": [
      "Trace the workflow: is anyone asked to enter these after the fact? Batch entry at the end of a shift is common and it is what creates the latency.",
      "Make the request recordable during the contact — a field the agent sets before ending the call — and capture the name and number together."
    ],
    "failureLooksLike": "A request written up at the end of the week is a week in which the number can still be messaged. The name is available while the person is on the phone and is never reconstructed afterwards."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-108/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-108.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}