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Illinois

Telecom Compliance Reference — Updated January 2024

Mini-TCPA State — High Risk

Calling Hours

8:00 AM–9:00 PM

Min Penalty

$50,000

Registration

Required

Overview Calling Hours Consent Registration DNC Enforcement Case Law Legislation

REI Wholesaling Telemarketing Compliance in Illinois

Real estate investor cold calling and SMS compliance in Illinois

Guide last reviewed: January 2025

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Mini-TCPA State — 815 ILCS 413/ (Restricted Call Registry Act)

Illinois imposes stricter consent and calling requirements than federal TCPA.REI Wholesaling companies operating here face $50,000 per-violation penalties.

Illinois REI Wholesaling Overview

Illinois is a HIGH-RISK state — arguably the most dangerous state in the country for non-compliant telemarketing. The layers of liability are staggering: ITSA (AG penalties up to $50,000), RCRA ($5,000/call AG + $500/call private action), ICFA ($50,000/violation for deception), criminal automated calling (Class B misdemeanor), and BIPA ($1,000-$5,000/violation with no cap for AI voice). Practical path for REI wholesalers: (1) Register with IL AG and post bond; (2) Manual dialing only for cold outreach, scrub both state and federal DNC; (3) Direct mail to drive inbound calls; (4) Build first-party consent with standalone written consent forms; (5) NEVER use AI voice, auto-dialers, or RVM on Illinois contacts without documented, comprehensive consent. The litigation environment in Illinois makes even minor non-compliance catastrophically expensive.

Penalty/Violation

$50,000

Willful

$50,000

Calling Hours

8:00 AM–9:00 PM

Private Suit

Allowed

Compliance Checklist

✓Register with the Illinois Attorney General as a telephone solicitor — $25,000 surety bond required,Scrub call lists against BOTH the Illinois Restricted Call Registry AND the federal National DNC Registry before EVERY campaign,Manual dialing for cold outreach — calling hours 8 AM to 9 PM,Obtain prior express written consent before ANY automated calling, texting, prerecorded messages, or AI outreach,If using AI voice: obtain SEPARATE BIPA consent (written, disclosing purpose and retention policy),Identify yourself, your company, and the sales purpose at the start of every call,Provide 3-day right to cancel any contract resulting from telephone solicitation,Honor opt-out requests immediately and maintain internal DNC list,EBR (18 months) applies to manual calls only and does NOT exempt from RCRA DNC scrubbing,Do NOT use ringless voicemail, auto-dialers, power dialers, or auto-text platforms without written consent,Maintain consent records for at least 5 years,Be aware of CRIMINAL penalties (Class B misdemeanor) for unauthorized automated calls,Illinois is the HIGHEST-RISK state for AI voice outreach — BIPA exposure alone can be catastrophic,Do NOT spoof caller ID — ICFA penalties up to $50,000 per deceptive act

What Gets Companies Sued

✗Top violations for REI wholesalers in Illinois: (1) Not registering with the IL AG or posting the $25,000 bond; (2) Using auto-dialers, CRM auto-send, or ringless voicemail without consent; (3) Not scrubbing the Illinois Restricted Call Registry (separate from federal DNC); (4) Failing to provide the 3-day cancellation right on phone contracts; (5) Using AI voice systems without BIPA-compliant consent; (6) Spoofing caller ID — common in REI but a $50,000 ICFA violation in Illinois; (7) Targeting elderly homeowners with high-pressure or deceptive tactics.

Special Exemptions

Licensed real estate brokers with active client relationships have an EBR exemption for manual calls only. EBR does NOT exempt from RCRA (must still scrub state DNC list). REI wholesalers without an Illinois DFPR real estate license have no agent-specific exemption.

Key State Rules

Mini-TCPAYes

RegistrationRequired

Class ActionsAllowed

Consent Requirements→Registration Details→DNC List→

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This is a compliance reference tool, not legal advice. Data compiled from public statutes, LegiScan, CourtListener, state AG offices, and AI-assisted analysis. Verify all information with qualified counsel before relying on it. Full terms & data sources →