Compliance & Call Recording Policy

1. Overview

[Placeholder] Crankshaft operates a compliant live transfer platform. This policy describes the compliance framework governing call origination, consumer consent, call recording, and agent obligations. Compliance is a shared responsibility between Crankshaft and agents using the platform.

2. TCPA Compliance

[Placeholder] All consumer leads delivered through the Crankshaft platform are sourced with prior express written consent (PEWC) as required by the Telephone Consumer Protection Act (TCPA). Crankshaft maintains consent records including:

• Timestamp and source of consent
• Specific disclosures acknowledged by the consumer
• IP address and session data at time of consent
• The specific products/verticals consented to

[Placeholder] Agents are responsible for their own TCPA compliance for any follow-up communications initiated outside the Crankshaft platform.

3. Do Not Call (DNC) Compliance

[Placeholder] Crankshaft scrubs consumer contact data against the National Do Not Call Registry and applicable state DNC lists prior to transfer. Agents must maintain their own internal DNC lists and honor consumer opt-out requests immediately. Crankshaft provides no warranty that a transferred consumer has not registered on a DNC list after the consent date.

4. Call Recording Disclosure

[Placeholder] Calls facilitated through the Crankshaft platform may be recorded. Crankshaft provides a disclosure to consumers at the time of connection. Agents are additionally responsible for providing any state-required two-party consent disclosures at the beginning of each call. States including California, Florida, Illinois, Maryland, Massachusetts, Montana, Nevada, New Hampshire, Oregon, Pennsylvania, and Washington require all-party consent for recording.

5. AI Screening and Verification

[Placeholder] Crankshaft uses AI systems to screen consumers for intent and compliance signals before a live transfer is connected. These systems assess factors including verbal consent confirmation, intent signals, and disqualification criteria. AI screening results are provided on a best-efforts basis and do not constitute legal compliance certification.

6. Agent Licensing Verification

[Placeholder] Crankshaft verifies insurance producer licenses via NPN at onboarding. Agents must maintain valid licenses in all states where they conduct business using the platform. Crankshaft may re-verify licensing at any time and will suspend access for unlicensed agents.

7. Telemarketing Sales Rule (TSR)

[Placeholder] Crankshaft operates in compliance with the FTC Telemarketing Sales Rule. Agents using the platform must also comply with TSR requirements including disclosure obligations, prohibited misrepresentations, and refund/cancellation policies.

8. State-Specific Insurance Regulations

[Placeholder] Insurance sales are heavily regulated at the state level. Agents are solely responsible for compliance with state-specific insurance regulations, including required disclosures, anti-rebating laws, and replacement regulations applicable in their licensed states.

9. Incident Reporting

[Placeholder] Agents must report any suspected compliance violations, consumer complaints, or legal notices received in connection with calls from the Crankshaft platform to compliance@crankshaft.ai within 48 hours.

10. Contact

Compliance questions: compliance@crankshaft.ai