The Reassigned Numbers Database
Yesterday the Federal Communication Commission (FCC) issued a final rule and order to create its proposed reassigned numbers database. This database will become a part of the FCC’s initiative Advanced Methods to Target and Eliminate Unlawful Robocalls, and will include the following:
- The most recent permanent disconnection dates for all toll-free numbers and serviced by providers in North America.
- 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.
The database enables callers to verify whether a telephone number has been reassigned before calling that number – instead of relying on previously obtained consumer consent. This will also protect consumers with reassigned numbers from receiving unwanted calls. Additionally, the FCC created a limited safe harbor from TCPA liability for those callers who rely on the reassigned database, so long as the callers can demonstrate they appropriately checked the most recent update of the database, and the database reported the number had not been reassigned.
While the new rule is effective March 26, 2019, compliance will not be required until the FCC publishes the Order in the Federal Register announcing compliance dates.
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