FCC Posts Rule Establishing Reassigned Numbers Database

The database rule, published in the Federal Register, is part of FCC methods to target and eliminate unlawful robocalls.

3/28/2019 11:00 AM

FCCGovernmentNewsStateTCPAAdvocacy
FCC Posts Rule Establishing Reassigned Numbers Database

The Federal Communications Commission’s rule to establish a comprehensive reassigned numbers database is in effect, although the official compliance date is pending.

In our immediate review of the ordering text, ACA has some concerns about ambiguity surrounding queries to the database using any last known date which the caller thought the person was located at that number. It appears it requires that the caller must use the date on which the express consent was received, and the caller has to prove that the date used in the query was the actual date one which the express consent was received.

ACA is examining whether this could pose unreasonable compliance challenges in knowing the exact date of consent given to creditors, and what steps may need to be taken for additional clarification in this area.

“The official text of the rule establishes a comprehensive reassigned numbers database which will contain the most recent permanent disconnection dates for all toll free numbers and all numbers issued and serviced by providers in North America. Additionally, there will be a minimum 45 day cooling off period required between the date a number is disconnected from one consumer and the date it is reassigned to another,” writes Mac Murray and Shuster associate Adam Steele in a report on the rule from the ACA International member firm.

The Federal Register notice announcing the database rule states a subsequent notice will outline official compliance dates for companies.

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.

ACA International’s multifaceted approach to Telephone Consumer Protection Act reform is highlighted in the FCC’s action on the reassigned numbers database. After seeking comment several times on the possibility of creating a reassigned numbers database, the FCC put out an order establishing a single, comprehensive reassigned numbers database that will enable callers to verify whether a telephone number has been permanently disconnected, and is therefore eligible for reassignment, before calling that number. However, many key questions on the reassigned numbers database will be answered in an expected additional ruling from the FCC which will deal with some of the key questions from ACA’s lawsuit challenging the 2015 Order.

ACA International members interested in discussing legislative and regulatory issues such as this with key policymakers, join ACA International’s advocacy staff May 14-16 in Washington, D.C. for the annual Washington Insights Fly-In. Registration is now open!

Related Content from ACA International:

FCC Reassigned Numbers Database Order Includes TCPA Liability Safe Harbor

FCC’s Action on Reassigned Numbers Database Punts Key Questions to Potential Ruling Stemming from ACA Litigation

FCC Unanimously Approves Rules for Reassigned Numbers Database

.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

FCC Posts Rule Establishing Reassigned Numbers Database

The Federal Communications Commission’s rule to establish a comprehensive reassigned numbers database is in effect, although the official compliance date is pending.

In our immediate review of the ordering text, ACA has some concerns about ambiguity surrounding queries to the database using any last known date which the caller thought the person was located at that number. It appears it requires that the caller must use the date on which the express consent was received, and the caller has to prove that the date used in the query was the actual date one which the express consent was received.

ACA is examining whether this could pose unreasonable compliance challenges in knowing the exact date of consent given to creditors, and what steps may need to be taken for additional clarification in this area.

“The official text of the rule establishes a comprehensive reassigned numbers database which will contain the most recent permanent disconnection dates for all toll free numbers and all numbers issued and serviced by providers in North America. Additionally, there will be a minimum 45 day cooling off period required between the date a number is disconnected from one consumer and the date it is reassigned to another,” writes Mac Murray and Shuster associate Adam Steele in a report on the rule from the ACA International member firm.

The Federal Register notice announcing the database rule states a subsequent notice will outline official compliance dates for companies.

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.

ACA International’s multifaceted approach to Telephone Consumer Protection Act reform is highlighted in the FCC’s action on the reassigned numbers database. After seeking comment several times on the possibility of creating a reassigned numbers database, the FCC put out an order establishing a single, comprehensive reassigned numbers database that will enable callers to verify whether a telephone number has been permanently disconnected, and is therefore eligible for reassignment, before calling that number. However, many key questions on the reassigned numbers database will be answered in an expected additional ruling from the FCC which will deal with some of the key questions from ACA’s lawsuit challenging the 2015 Order.

ACA International members interested in discussing legislative and regulatory issues such as this with key policymakers, join ACA International’s advocacy staff May 14-16 in Washington, D.C. for the annual Washington Insights Fly-In. Registration is now open!

Related Content from ACA International:

FCC Reassigned Numbers Database Order Includes TCPA Liability Safe Harbor

FCC’s Action on Reassigned Numbers Database Punts Key Questions to Potential Ruling Stemming from ACA Litigation

FCC Unanimously Approves Rules for Reassigned Numbers Database

.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

Loading...

Loading...

Scroll to Top