The Federal Communications Commission’s Reassigned Numbers Database is designed to prevent a consumer from getting unwanted calls intended for someone who previously held their phone number. Telemarketers can use the database to determine whether a telephone number may have been reassigned so they can avoid calling consumers who do not want to receive the calls.
Telemarketers that use the database can also reduce their potential Telephone Consumer Protection Act (TCPA) liability by avoiding inadvertent calls to consumers that have not provided consent for the call.
The Reassigned Numbers Database can be found at www.reassigned.us.
How Can the Reassigned Numbers Database Help Telemarketers
Telemarketers are able to check before making a call to find out if the phone number may have been reassigned. If the database wrongly indicates that the number has not been reassigned, the caller may be protected against TCPA liability when placing the call. Consult with a seasoned TCPA lawyer if you have received a demand letter from a TCPA plaintiff’s attorney or been named as a defendant in a lawsuit.
Recordkeeping Requirements for Service Providers
Service providers are required to maintain records of the most recent date that each telephone number assigned to one of their subscribers was permanently disconnected. Additionally, all service providers are required to age telephone numbers for at least 45 days after permanent disconnection prior to reassignment.
On the 15th of every month, all service providers must report permanent disconnections of their subscribers' telephone numbers to the Reassigned Numbers Database Administrator. Providers are required to submit disconnected number data to the RNDA in accordance with prescribed technical specifications.
If a provider does not have new permanent disconnections to report for a monthly period, that information must be submitted to the administrator.
How Telemarketers Can Query the Reassigned Numbers Database
Subscriptions are available for purchase and telemarketers can check to see if a telephone number is still assigned to the consumer they are trying to reach. Doing so may reduce their calls to consumers who have reassigned numbers and who may not wish to receive such calls.
Telemarketers enter a phone number they wish to call, and either the date the caller obtained consent from the consumer or the last date the caller was able to verify that the consumer was at that telephone number. Callers may query individual numbers or groups of numbers.
The database returns one of three responses: "Yes," "No," or "No Data."
Yes — indicates the number has been disconnected, and possibly reassigned, after the date provided, and the telemarketer should not call the number unless they have separate consent from the current holder of the number.
No — indicates the number has not been disconnected or reassigned and the telemarketer can place the call provided they have obtained consent from the consumer, if consent is required under the TCPA.
No Data — indicates the queried number is not contained in the database and the date provided in the query is before the date all providers were required to maintain records of disconnected numbers.
What is the Reassigned Numbers Database TCPA Safe Harbor
To be shielded from liability under the TCPA, a telemarketers caller must prove that: (i) it obtained consent from the intended call recipient; (ii) it or its duly authorized agent checked the database prior to calling the number to verify that the number had not been permanently disconnected, or reassigned, after the date the caller obtained consent; and (iii) the database returned a query response of “no”" that was incorrect.
Are There Fees for Using the TCPA RND?
Yes. Users of the RND database are required to subscribe and pay a fee.
The RND offers different subscription tiers and discounts. Those wishing to use the RND may sign up for a one-month, a three-month, a six-month, or an annual subscription.
On November 26, 2024, the Consumer and Government Affairs Bureau announced a subscription change that became effective February 5, 2025. The change allows a subscriber to roll over its unused queries when it purchases a new subscription prior to the end of its subscription term. On April 7, 2025 the database administrator announced modified interim pricing effective April 28, 2025. The new pricing adds two additional tiers and lower prices for all tiers.
The database became operational for paid subscribers in 2021.
Takeaway: The newly FCC Reassigned Numbers Database is an important tool for lead generators and telemarketers that can minimize TCPA liability exposure. In order to take advantage of the safe harbor provided by the RND, lead generators and telemarketers must enroll, establish a protocol for checking numbers and scrub reassigned numbers against the RND before calling or texting.
Contact an experienced TCPA lawyer to discuss the implementation of preventative telemarketing compliance measures designed to fend off Telephone Consumer Protection Act claims, including, but not limited to, allegations involving unsolicited telemarketing calls and texts to a wireless line using an automated system or pre-recorded message without first obtaining prior express written consent of a recipient or business.
