DNC Procedures and Training should be developed and enforced properly.
This is becoming a need of the time to now about the various laws coming and being enforced know a day for marketing a product especially the DND rules i.e. the Do Not Disturb. It is therefore very much necessary that broker should get proper training on this and get a proper understanding of this and training the agents accordingly. It's highly likely that the government will hold brokers responsible for the telephone marketing practices of their agents. Develop a Policy Manual with clear guidelines and training, or at least an orientation that makes the rules clear to your agents. Record their attendance with a signature of understanding.
Relying on the Safe Harbor Provisions can be dangerous.
The procedures and training are specifically mentioned in the Safe Harbor Provisions of the DNC act. However, recent enforcement actions have shown that the government is very strictly interpreting what is allowed to be an "inadvertent error".
The only safe approach is to have a strict policy, train your agents on it, and enforce it.