SIE Ready🛡️ Compliance Considerations · Lesson 6 of 6 · 5 min
Cold Calls and Complaints
☎️ A cold call at 9:15 p.m. can break a federal rule and a FINRA rule at once. The complaint that follows has its own rules too.
💡 Key idea
Call only 8 a.m.–9 p.m. the customer's local time; honor do-not-call requests. Written complaints: kept 4 years, reported quarterly by the 15th.
🧠 Why it matters
Under FINRA Rule 3230, cold calls to a home are allowed only from 8 A.M. TO 9 P.M. in the CALLED PERSON'S local time, and callers give their name, the firm's name, a contact number and the sales purpose. A person who asks not to be called goes on the FIRM'S DO-NOT-CALL LIST, honored within 30 days at most. NATIONAL DO-NOT-CALL REGISTRY numbers are off-limits unless an exemption applies: an established business relationship (account activity within 18 months, or an inquiry within 3 months), prior written consent, or a personal relationship. Written customer COMPLAINT records are kept 4 years (Rule 4513), and complaint statistics go to FINRA quarterly, by the 15th of the following month (Rule 4530).
📈 In the real world
🕘 Working late in New York at 10:30 p.m., rep Tasha wants to call a prospect in Los Angeles, where it is 7:30 p.m. That is inside the window, so she may call. A prospect in Boston would have to wait until 8 a.m. tomorrow. The window is the customer's clock, not hers.
📌 Takeaways
- 8 a.m. to 9 p.m., measured in the called person's local time
- Firm do-not-call requests honored within 30 days; national registry has limited exemptions
- Written complaints: 4-year records; quarterly statistics to FINRA by the 15th
📖 Terms in this lesson
Do-not-call list: The national registry and each firm's own list of people who must not receive telemarketing calls.
Telemarketing calling hours: Cold calls may be made only between 8 a.m. and 9 p.m. in the called person's local time.
BREAKFAST TO BEDTIME (8 to 9): Cold calls only from 8 a.m. to 9 p.m., in the called person's local time.
✅ Test yourself
A rep in Chicago (Central time) wants to cold-call a prospect in Denver (Mountain time). What is the latest the rep may place the call, Chicago time?
- 9:00 p.m.
- 11:00 p.m.
- 8:00 p.m.
- 10:00 p.m.
Answer: D · 10:00 p.m.
The window is 8 a.m. to 9 p.m. in the called person's time. 9 p.m. in Denver is 10 p.m. in Chicago, so 10 p.m. Chicago time is the latest. Using the caller's own clock gives the wrong answer of 9 p.m.
Which call to a number on the national do-not-call registry is permitted?
- A call to a person whose friend gave the rep the number
- A call to a person who opened an account 6 months ago
- A call to a person who saw the firm's billboard last week
- A call to a person who last traded with the firm 4 years ago
Answer: B · A call to a person who opened an account 6 months ago
An established business relationship exists when the person had an account or transaction with the firm within the last 18 months. Four years is too long, and a referral or seeing an ad does not create a relationship.
By what date must a firm report its statistical customer complaint data for a calendar quarter to FINRA?
- Within 30 days of each complaint
- The 15th of the month after the quarter
- The last day of the quarter
- The 5th business day after the quarter ends
Answer: B · The 15th of the month after the quarter
Rule 4530 requires quarterly complaint statistics by the 15th day of the month following the quarter. The 30-calendar-day deadline applies to reportable events such as certain regulatory actions, not routine statistics.
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