Calls, texts and consent
Before an AI phone agent calls or texts your customers: hours, consent and opt-outs.
Four things to settle before any AI phone agent reaches out to a customer: when it may call, whom it may contact, how a customer opts out, and whether calls are recorded. Here is what Cleo does for each, what the FCC has said about AI voices, and what stays with your dealership.
The short answer
What should a dealership check before an AI phone agent calls or texts customers?
Check four things: when it may call, whom it may contact, how a customer opts out, and whether calls are recorded. The FCC ruled in February 2024 that calls using AI technologies that generate human voices fall under the TCPA and need the prior express consent of the called party, absent an emergency purpose or exemption. Cleo adds guardrails around that: every campaign call goes out only while the calling schedule you set is open, a contact flagged do not call is not called, the first text carries a STOP line, and calls can open with a recording notice. Whether you hold consent for a given customer is your dealership's call, with your counsel.
This page describes product behavior and public sources. It is not legal advice.
Product behavior
Four checks, and where each one stops.
When it calls.
For an internet lead, the window for the first call is 8 a.m. to 9 p.m. in the customer's local time, taken from the lead's ZIP code, then the phone number's area code, then your dealership's time zone. Every campaign call is dispatched only while the campaign is active and the calling schedule you picked is open, in your dealership's time zone. A call that comes due while the schedule is closed waits until it opens.
Whom it calls.
Cleo checks do-not-call flags. A call is not dispatched to a contact flagged do not call by voice, a scheduled call to a contact flagged afterwards is closed, and a lead marked do not contact ends the sequence. Cleo also stops once the customer replies by text, books, or answers a call.
How a customer opts out of texts.
The first text Cleo sends a contact includes the line "Reply STOP to opt out, HELP for help." When a contact replies STOP, Cleo saves the opt-out against that number. Before a text about a call, Cleo can also ask the caller for explicit consent, read the consent question word for word, and record whether the caller agreed or declined.
Whether calls are recorded.
Where the recording notice is switched on, a call opens with a fixed pre-recorded clip saying the call is being recorded for quality assurance purposes, played before Cleo greets the caller. It can be set for a single phone line or for the whole dealership.
On an outbound call, if the person asks whether Cleo is a real person, Cleo says it is the dealership's virtual assistant.
The public record
Two sources every buyer should read.
FCC 24-17
Declaratory Ruling adopted February 2, 2024 (released February 8, 2024): AI technologies that generate human voices fall under the TCPA’s artificial or prerecorded voice rules
47 CFR 64.1200(c)(1)
No telephone solicitation to a residential subscriber before 8 a.m. or after 9 p.m., local time at the called party’s location
On February 2, 2024, the FCC adopted a Declaratory Ruling (FCC 24-17, released February 8, 2024). It confirms that the TCPA’s restrictions on an artificial or prerecorded voice cover current AI technologies that generate human voices. Calls that use them require the prior express consent of the called party to initiate, absent an emergency purpose or exemption. Separately, the public regulation at 47 CFR 64.1200(c)(1) says no person or entity shall initiate a telephone solicitation to a residential telephone subscriber before 8 a.m. or after 9 p.m., local time at the called party’s location. Both are public rules and not Cleo results.
Which rules apply to a given call depends on who is called, why, and what consent your store holds. Your counsel decides that, not a software vendor.
Your side of the line
Software can follow your rules. It cannot hold your consent records.
What stays with your dealership
Consent is a record your dealership holds for each lead source and each list. A calling schedule set in your dealership’s time zone is only inside a customer’s window if you set it that way for customers in other time zones. Your counsel decides what your store needs, and what each lead form says to the customer.
Six questions for any vendor, 1 to 3
1. Whose clock sets the calling hours: the customer’s, or the dealership’s?
2. What happens to a call that comes due after hours: is it dropped, or held until the schedule opens?
3. How does a do-not-call flag reach the dialer, and what happens to calls already scheduled?
Six questions for any vendor, 4 to 6
4. Does the first text carry an opt-out line, and where is a STOP reply stored?
5. Can the call open with a recording notice, set per phone line?
6. What does the agent say when a customer asks whether it is a real person?
FAQ
Still have questions?
Does the TCPA apply to AI-generated voices?
The FCC said so in a Declaratory Ruling adopted February 2, 2024. It confirms that the TCPA's restrictions on an artificial or prerecorded voice cover current AI technologies that generate human voices, so calls that use them require the prior express consent of the called party, absent an emergency purpose or exemption. This is a public ruling and not legal advice.
What hours does Cleo call in?
Does Cleo call numbers flagged do not call?
How does a customer opt out of texts?
Does Cleo ask for consent before texting a caller?
Before a text about a call, Cleo can ask the caller for explicit consent, read the consent question word for word, and record whether the caller agreed or declined.
Can calls open with a recording notice?
Does Cleo say it is an AI?
How does a customer opt out of texts?
Contact
Bring your compliance questions to the demo.
Book a demo and walk through calling schedules, opt-outs and the recording notice for your stores with someone who can show each setting.
