You seem to be unaware that a "Survey" that also contains a sales solicitation is specifically mentioned in the DNC rules ... that call is NOT classified as a survey, and IS a violation.
Scammers / spammers need not look for loopholes in the DNCL. They just ignore the DNCL, and continue their criminal activities.
217 629-4171 Spam call....In 10 years I have never received a legitimate sales call from a REAL telemarketer. They sometimes claim to be a survey. It is an attempt to make themselves look legitimate. They have called numerous times saying I have won a free trip to the Bahamas.