Our marketing department is getting ready to do a calling blitz. They want to call people who are on the National Do Not Call list stating that they fall under the exception because they are customers. The only catch is these people only hold agent or authorized signer status. Would these people be considered customers? It isn't defined in the FCC rules. Leaning toward definitions applied in other bank regulations such as CIP it is my feeling that the corporation or business is the actual customer not the agent or authorized signer and therefore calling them would be a violation of their opt out rights.

Any thoughts on this?

I cannot imagine a faster way to lose business.

If I was an agent on an account, and I got a call basically saying "Na na na na na! we can call you all we want", I would either do everything in my power to let the account owner or my employer know.

I am totally with you on this one.

I agree. And if you are right (the business is the customer, not the signer) you could be subject to $11,000 fine per call to individuals on the DNC list. So you risk making your customer, or potential customer, mad and risk the possibility of monetary penalties. Someone needs to take this one back to the table for a second look.