I've searched but can't seem to find a good answer. Looking strictly at the Do Not Call Rules (I don't want to complicate with FACT Act or Privacy, but I know those rules and the impact).
We are a bank, with a broker/dealer (bd)affiliate. We share bank customer information with the bd for marketing purposes. The bd is making calls to these customers, most of whom would not be existing customers of the bd.

Doesn't the bd need to run the list of names by the DNC lists before making these calls? The bd has been relying upon the customer's established relationship with the bank as an exemption from this requirement.

Where did the dust settle on this issue? Some articles consider the companies affiliates to fall into the exemption, some articles don't.

I really need some help on this.

From FTC's Facts for a Business page:

To whom does the established business relationship apply?

An established business relationship is between a seller and a customer; it is not necessarily between one of the seller’s subsidiaries or affiliates and that customer. The test for whether a subsidiary or affiliate can claim an established business relationship with a sister company’s customer is: would the customer expect to receive a call from such an entity or would the customer feel such a call is inconsistent with having placed his or her number on the National Do Not Call Registry.