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Can real estate investors text a purchased list? TCPA and 10DLC explained
A phone number is not permission. Buying a property-owner list or paying to append mobile numbers does not, by itself, give you consent to text those people.
The short answer
Do not upload a purchased or skip-traced list to a texting CRM and assume it is ready for a campaign. The list may help you research properties. It does not prove that the person agreed to receive your messages, that the number is still theirs, or that your sending provider permits the use.
For a Twilio-based workflow, the provider's policy is especially clear: get consent before messaging, keep proof, and do not buy, sell, rent or transfer consent. Promotional messages require prior express written consent under that policy. A seller's claim that a list is "opted in" is not a substitute for your own documented, permitted opt-in process.
Three different checks, not one approval
| Check | What it covers | What it does not do |
|---|---|---|
| TCPA and other laws | Consent, solicitation restrictions and consumer rights where applicable | Make every campaign legal just because it is sent manually |
| Provider and carrier policy | Permitted traffic, sender identity and opt-out requirements | Replace state and federal law |
| A2P 10DLC registration | Register the business and campaign using U.S. local numbers | Give permission to contact a person |
What the TCPA means for real estate texting
The federal rule restricts certain automated calls and texts, including consent requirements for covered marketing. The legal analysis depends on the technology, the recipient and what the message does. An offer to buy someone's property can raise different questions from advertising a service. Do not treat either a "cash offer" label or a manual-send button as a blanket exemption.
National and company-specific do-not-call obligations can apply to covered solicitations. State laws may add restrictions. Have counsel decide which requirements apply to your business, then make them part of the system rather than leaving each employee to guess. Passing a do-not-call check is not the same as having permission under your messaging provider's policy.
What A2P 10DLC actually does
Twilio says anyone sending SMS or MMS from an application over a U.S. 10-digit local number to U.S. recipients must register for A2P 10DLC. The process identifies the brand and campaign, including the opt-in method and example messages. Toll-free numbers and short codes use different routes and requirements; they are not consent shortcuts.
Registration is a delivery requirement, not a license to cold-text. An approved campaign can still be blocked or suspended for unwanted traffic. Rotating numbers to get around filtering is not a fix: Twilio prohibits spreading similar messages across numbers to evade unwanted-message detection.
Build a lead flow you can explain
- Get a direct opt-in. Use a clearly described web form, in-person process or inbound request. Identify your business and the kind of messages the person is choosing. Have the wording reviewed.
- Keep the evidence. Store the phone number, timestamp, source, exact disclosure/version and evidence of the person's affirmative action. Record what topics they agreed to receive.
- Keep the scope narrow. A question about one property is not permission for an indefinite marketing sequence. Twilio allows a response to an inbound request but says that exchange does not authorize recurring engagement.
- Check before each send. Verify consent scope, suppression status, applicable do-not-call rules and allowed local sending times.
- Make stopping easy. Include sender identification and the required opt-out wording. Suppress stop requests immediately in your workflow, including scheduled messages.
STOP is not the only way someone can say no
Recognize standard opt-out words and ordinary language such as "please don't contact me again." Under the federal rule, reasonable revocations must be honored within a reasonable time, no more than ten business days where that rule applies. That outer limit is not a reason to keep sending. Twilio's policy prohibits subsequent messages after opt-out except one final confirmation; design for immediate suppression.
A narrow FCC waiver postpones the requirement to apply a revocation from one informational message type to unrelated matters until January 31, 2027. It does not suspend other consent-revocation obligations. Do not use that delay to continue the campaign the person stopped. Provider rules may be stricter.
What your CRM should record
Keep consent and suppression separate from sales status. A lead marked "warm" can still be opted out. Give the team a shared suppression list, an audit trail, inbound reply handling, pending-message cancellation and a way to resolve unclear consent. Test all of those before launching.
Does TextCRM make a campaign compliant?
No software can certify your list, consent language or legal position. TextCRM is offered for opted-in contacts and scoped to your business. Ask what the setup records and blocks, and have your legal reviewer assess the campaign itself.
Can I text a purchased list just to ask for permission?
Do not assume a permission request is exempt. It is still a message to someone who has not opted in, and Twilio requires consent before sending. Choose a lawful, provider-permitted way to build an opt-in audience instead.
Sources and review notes
- 47 CFR 64.1200: federal delivery, solicitation and revocation rules.
- Twilio Messaging Policy: updated April 13, 2026; consent, proof, sender identity and opt-out rules.
- Twilio A2P 10DLC documentation: registration and number types.
- FCC January 6, 2026 waiver order: the limited delay to January 31, 2027.
Recheck these sources before launching or changing a campaign. This page is not a state-by-state compliance checklist.