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I'm assuming that by a "5 ARM," you are referring to a 5/1 adjustable rate mortgage that is about to hit its first reset date, a typical time for adjustable rate mortgage holders to refinance. Many mortgage loan servicers proactively solicit their customers for this refinance opportunity through the call center.
The basic rule regarding outdialing, whether it's fully automated or manual, is that enterprises can call a customer with whom they have a pre-existing relationship, according to the do not call list. Presumably, you have such a relationship when functioning as an "outsourcer" representing a mortgage company, since you are acting as their agent and dealing with their customer. However, you still have to be careful to observe all applicable call center outbound calling regulations. I suggest that you contact the Direct Marketing Association (DMA) and/or the Federal Communications Commission (FCC) for more information. You may want to look at their Web sites and direct any inquiries via email. If necessary, you can always check in with a lawyer who specializes in this area of regulation.
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