What Happened in the $14 Million American Income Life Insurance Do Not Call Case?

In August 2025, American Income Life Insurance agreed to a $14 million settlement resolving a class action lawsuit alleging violations of the Telephone Consumer Protection Act (TCPA).

The allegations centered on telemarketing calls placed to nearly 50,000 phone numbers listed on the National Do Not Call (DNC) Registry.

For businesses that rely on outbound calling, this case raises at least two important questions:

What specifically went wrong? And how can similar exposure be avoided?

The Core Allegations of Fuld v American Life Insurance Company

According to the class action complaint, the allegations included:

• Multiple calls within a 12-month period to numbers registered on the National Do Not Call Registry
• Calls occurred more than 30 days after registration
• Continued calls after a consumer explicitly requested they stop
• Failure to adequately maintain internal do-not-call procedures
• Use of spoofed numbers, complicating identification

The structure of the allegations reveals how DNC risk often develops.

Why More Than One Call Matters

Under the TCPA, more than one call within a 12-month period to a registered number can trigger liability. Statutory damages may reach $500 per violation and up to $1,500 if willful.

When multiplied across thousands of calls, risk compounds quickly.

DNC liability is rarely triggered by a dramatic compliance failure. It usually results from repetition combined with process failure.

The Three Layers of Do Not Call Compliance

When teams think about DNC compliance, they often picture a single list.

In practice, there are three.

1. Federal Registry Compliance

The National Do Not Call Registry is the baseline.

• Numbers registered for more than 30 days should not be called for telemarketing purposes.
• More than one call within 12 months may create a private right of action.
• The federal registry updates daily.

A one-time download is not a durable defense.

2. State Registry Compliance

Many states maintain their own do-not-call registries or impose additional telemarketing requirements.

States may also require separate registration, impose additional disclosure rules and/or expand enforcement rights.

Federal compliance is the floor but states are allowed to raise the ceiling.

If scrubbing processes address only the national list, a caller would not be insulated from state-level exposure.

3. Internal Do Not Call Requests

The most operationally complex DNC risk often arises from internal opt-out handling.

Under 47 C.F.R. § 64.1200(d), companies must:

• Maintain a written do-not-call policy
• Train personnel on that policy
• Record do-not-call requests at the time they are made
• Honor those requests within 30 days
• Maintain those records for five years

The complaint in this case alleges failures tied to internal DNC handling.

These breakdowns can result from a long list of potential oversights:

• Opt-outs logged in one system but not synced to dialers.
• Multiple vendors operating from different suppression files.
• Manual overrides bypassing centralized controls.
• Inconsistent training across sales teams.

Individually, these look like small operational gaps. Collectively, they can result in repeated calls to someone who has already asked to be left alone.

Strong internal DNC compliance depends on synchronized systems and disciplined workflows that are applied consistently across teams and vendors.

It is important to know that a company can scrub against the federal and state lists and still face exposure if internal requests are mishandled.

The Role of Spoofing and Identification

The complaint also alleged the use of spoofed numbers, which complicates identification.

Even when spoofing is used for call routing or reputation management purposes, it introduces evidentiary complexity. If a consumer cannot clearly identify the caller, disputes escalate more quickly. When identification practices are unclear, call records become harder to defend.

In DNC litigation, documentation often determines the outcome. If multiple vendors are dialing, if dynamic numbers rotate, or if caller ID practices are inconsistent, documentation must be precise enough to reconstruct the full path of the call. 

In practice that means being able to answer these questions:

Can you show when a number was scrubbed?

Can you demonstrate when an opt-out was logged?

Can you verify which vendor placed which call?

Can you trace the suppression file used for a given campaign?

When those records are fragmented, even compliant intent becomes difficult to demonstrate under scrutiny.

A Practical DNC Health Check

If you’re reviewing your own outbound controls, a few practical questions can clarify risk:

• Are you scrubbing against the National DNC Registry at least every 30 days?
• Are state registries incorporated where required for your operations?
• Are internal opt-out requests centralized?
• Are do-not-call requests honored within 30 days?
• Are requests retained for five years?
• Can you demonstrate written policy and employee training if challenged?

Uncertainty in any of these areas isn’t a crisis, but it does indicate a need to revise processes.

The Larger Lessons from Fuld v American Life Insurance Company

The American Income Life case is not unusual by any means. What makes it instructive is how ordinary the alleged failures were.

It wasn’t the result of new rules, one bad list or a novel campaign. Just federal registry coverage, state-level obligations, internal opt-outs, and documentation. The same components every organization works with.

The $14 million price tag is an indication of what can happen when those components operate in parallel instead of alignment.

That is how DNC risk builds for the average business: not through dramatic misconduct, but through everyday workflows that aren’t coordinated tightly enough across systems and vendors.

That’s why the fundamentals still matter. They're not flashy, but they're what keep businesses protected.

If you’d like to walk through your current DNC structure with someone who lives in these details every day, we’re always available to have that conversation.