This is the cheapest compliance failure to avoid and one of the most common, because it is invisible from inside a single-office floor. Nobody in the room is doing anything unusual; the dialler is simply calling people for whom it is the wrong time.
| Office time (ET) | What it is in PT | Permitted? |
|---|---|---|
| 8:00am | 5:00am | No |
| 9:00am | 6:00am | No |
| 11:00am | 8:00am | Yes |
| 5:00pm | 2:00pm | Yes |
| 9:00pm | 6:00pm | Yes |
The east-to-west problem is a morning problem and the west-to-east problem is an evening one. A California floor calling New York at 5pm local is calling at 8pm, which is inside the federal window and outside some state ones.
Configure it once, properly
- Store the merchant’s state or area-code time zone on the record at ingestion, not at dial time.
- Set the dialler to derive the window from that field, with the strictest applicable rule.
- Apply the same window to texts unless you have checked that the state treats them differently.
- Hold a hard stop rather than a soft warning. A warning is something a rep dismisses.
The commercial argument is the same
Calls placed at 6am do not fund deals. They wake people up, they burn a record you paid for, and they produce exactly the complaints that lead to suppression requests and worse. The compliance case and the conversion case point the same direction here, which is not true of every rule.
Questions brokers ask
What hours can you call a merchant?
Federally, between 8am and 9pm in the called party’s time zone. Several states are tighter, so a national floor should either geo-fence by state or run everywhere at the strictest applicable window.
Whose time zone counts?
The merchant’s, not yours. This is the mistake floors make when they expand — a 9am east-coast start is a 6am call in California, which is a violation before the rep has said anything.
Do calling hours apply to text messages?
Treat them as though they do. Several states address texts explicitly and some apply different windows, so applying the voice window to SMS is the safe default unless you have checked otherwise.
Can you rely on the area code for time zone?
Only as a fallback. Mobile numbers travel with their owners, so an area code is weak evidence of location — use the business address the application captured where you have it.
Does calling early actually cost anything commercially?
Yes. A 6am call does not fund a deal, it burns a record you paid for and it generates the complaints that produce opt-outs. The compliance case and the conversion case agree here.
Alex Makowski
Founder, Infinite Bookings
Runs the lead generation operation behind Infinite Bookings — paid traffic, the funding application, and the delivery pipeline that puts records into brokers’ CRMs.
Reachable directly at alex@infinitebookings.com or 732-609-7182.