This month, voice service providers will be required to verify consumers’ telephone numbers and maintain records in the database.
The Federal Communications Commission’s rule to establish a comprehensive reassigned numbers database has a compliance date for voice service providers of July 27.
The rule took effect in March 2019 without the release of a compliance date, ACA International previously reported.
The reassigned numbers database enables callers to verify the status of a phone number and helps protect consumers with reassigned numbers from receiving unwanted calls.
Beginning July 27, 2020, voice service providers must maintain records of the most recent date each number was permanently disconnected and must age telephone numbers for at least 45 days after disconnection and before reassignment, according to a news release from the FCC.
Small business voice service providers have an additional six months, i.e., until Jan. 27, 2021, to comply with the record maintenance rule. The FCC will announce the compliance date for the new rule requiring voice service providers to send information to the Reassigned Numbers Database once the database is established, according to the news release.
ACA filed comments earlier this year outlining issues the FCC should consider when implementing the database.
The FCC, by a unanimous vote in December 2018, decided to take additional steps to create the database designed to enable callers to verify the status of a phone number and help protect consumers with reassigned numbers from receiving unwanted calls.
In its most recent comments, ACA argued that despite the commission’s recent actions to operationalize a new reassigned numbers database, callers continue to face the prospect of class-wide TCPA litigation exposure based on a single call to a reassigned number. Nothing in the Technical Requirements Document will resolve these concerns, and the reassigned numbers database, after facing multiple implementation delays already, is still nowhere near completion.
ACA, in its comments, asked the commission to clarify that:
1) The TCPA’s statutory phrase “called party” means the “expected” or “intended” recipient; and
2) The TCPA allows callers to “reasonably rely” on the “prior express consent” that they had received.
ACA is continuing to follow the progress of the reassigned numbers database and push for additional clarity from the FCC.
The term “called party” should be given additional consideration considering ACA’s decision in the D.C. Circuit striking down the 2015 Ruling and Order.
ACA is seeking feedback about your concerns, specifically whether there are any cost burdens that could result from the FCC’s plans for the database. Please send thoughts and information to Leah Dempsey, Vice President and Senior Counsel, Federal Advocacy, at [email protected].
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