FCC Issues Supplemental Guidance for Reassigned Numbers Database Users

The guidance provides clarity on query responses in the FCC reassigned numbers database and when the TCPA safe harbor applies.

01/06/2022 3:30 P.M.

4.5 minute read

The Federal Communications Commission’s Reassigned Numbers Database became fully operational on Nov. 1, 2021, and the commission has now released supplemental guidance to improve the utility of the database and enhance callers’ ability to avoid making unwanted calls to consumers.

Now that the database, which had been in development since 2018, is live, callers can check it to “ensure they reach consumers that expect their calls and avoid calling consumers with reassigned numbers who may not wish to receive the call,” according to the FCC’s supplemental guidance.

The reassigned numbers database helps callers by returning one of three responses to explain whether the number has been reassigned (or, more accurately, permanently disconnected) since the date provided: “yes,” “no,” or “no data.”

Callers using the database have reported receiving a high number of “no data” responses to their queries, and many of the “no data” responses appear to be a result of how the queries are defined in the database, according to the FCC.

Voice service providers were required to maintain records of consumers’ phone numbers by Jan. 27, 2021, after the FCC’s Consumer and Governmental Affairs Bureau issued guidelines for using the database in April 2020.

Voice service providers were required to begin reporting permanent disconnections to the reassigned numbers database administrator by Oct. 15, 2021, and on a monthly basis thereafter.

Now that the database has been active for a few months, the FCC has data to evaluate users’ experiences—especially the call query responses.

“When querying the database, callers input a phone number and a ‘date of consent,’ which is either the date when the caller obtained consent from the consumer to call the number or a date when the caller could be reasonably certain that the consumer could still be reached at that number,” according to the FCC.

However, because of the break in time between when voice service providers had to start maintaining data on disconnects (January 2021) and when they officially had to report the data (October 2021)—the database has started to return a “no data” response to callers even though the database contains actionable information regarding whether the number has in fact been disconnected.

The “no data” responses fail to indicate if a phone number has reassigned to a different consumer or disconnected, and are not as useful as a “yes” or “no” response—causing a reluctance among subscribers to use the database.

To remedy the issue, the FCC has additional interpretation on when the database should return a “no” or “no data” response:

“At a high level, the meaning of the results, as prescribed by the Reassigned Numbers Order, remains unchanged: ‘yes’ means the number has been disconnected subsequent to the caller having received prior express consent to call the number, ‘no’ means the number has not been disconnected (and would have been in the database if it had been disconnected), and ‘no data’ means the database does not contain the relevant data to determine whether the number has been disconnected during the time of the query. This supplemental interpretation maximizes the usefulness of the Reassigned Numbers Database by providing callers with the greatest amount of actionable information, in light of the fact that the database went live on November 1, 2021, and it contains data from all service providers from January 27, 2021. The Reassigned Numbers Database Administrator has indicated that the change is technically feasible to make in a timely manner.”

It’s important to note that callers who receive a “no” query when using the database may be eligible for the safe harbor from liability for calling that consumer while calling a consumer with a number matching a “no data” query does not come with the safe harbor.

ACA Advocates for TCPA Safe Harbor

ACA International supported efforts to develop a concise reassigned numbers database, urging the FCC that it be reasonably priced, accurate and easy to use and include a safe harbor, ACA previously reported.

The FCC created a rule in 2018 to establish the database, which enables callers to verify the status of a phone number and helps protect consumers with reassigned numbers from receiving unwanted calls.

ACA has had many discussions with the FCC about the reassigned numbers database.

A beta test of the database, which ended Sept. 30, 2021, helped the administrator determine the appropriate subscription tiers and rates for the database. Callers are required to pay to use the database, ACA previously reported.

The reassigned numbers database will only tell callers the most recent disconnection date of the number they last called. Callers should consider how this impacts their overall calling strategy.

The administrator may adjust the tiers and rates monthly, pending FCC approval.

Finally, the FCC may initiate a proceeding to establish a more permanent rate structure, which would go into effect no sooner than Jan. 1, 2023. In the meantime, the FCC encourages users to provide online feedback to the administrator regarding its tiers and rates.

Learn More About the Reassigned Numbers Database

Beth Sprague, director of the FCC’s reassigned numbers database, and David Kaminski, partner at Carlson and Messer, explained more about the database and the Telephone Consumer Protection Act safe harbor associated with using it on a recent ACA Huddle, which is available for members here.

If you would like to share any thoughts or feedback on the reassigned numbers database pricing structure and its functionality, contact ACA International’s Vice President and Senior Counsel, Federal Advocacy Leah Dempsey at [email protected]

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