If a consumer has an Arizona mailing address but a Florida cell, which local time should we follow for the 8 a.m.–9 p.m. window? I’m auditing dialer logs this week and want to be sure our scrubs line up with Reg F/FDCPA.
I’d go belt-and-suspenders and scrub to the intersection — only call when it’s 8–9 in both the AZ address time and the FL area-code time — unless you know the consumer’s current location, since Reg F keys off “consumer’s location.” Add a dialer rule that checks both zones and log the basis; reg text here: https://www.consumerfinance.gov/rules-policy/regulations/1006/6/#b-1. Do you capture a preferred time zone during verification?
Small tweak that saves headaches: add a 15–30 minute buffer to your 8 a.m./9 p.m. windows based on your safe‑harbor pick so DST flips and clock drift don’t burn you at the edges. Also, @lewis8 is right on DST — one carve‑out: “Navajo Nation in AZ does DST,” so if the mailing ZIP hits that footprint, treat it seasonal; do you have a ZIP/county flag for that?
Piggybacking on @oliver58: when the mailing and phone locales disagree, I’d throttle calls to the overlap of both 8 a.m.–9 p.m. windows until you re-verify — belt-and-suspenders but it prevents edge burns. For an Arizona address plus a Florida cell in summer, that’s roughly 11 a.m.–9 p.m. ET (9 a.m.–7 p.m. AZ).