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A DANGEROUS TCPA PITFALL


Reassigned Numbers Database (RND)



Wireless use has skyrocketed. Organizations who ignore the probability that a phone number may have changed owners are playing a dangerous regulatory game of chance




Reassigned Numbers Database Overview

A FOUNDATION OF NECESSITY

Reassigned Numbers Database Overview

In November 2021, the Reassigned (Telephone) Numbers Database (RND), commissioned by the FCC, became available for production use. This database allows Callers and Caller Agents to upload data in a specific format to validate the status of a phone number (i.e., whether or not the number has been permanently disconnected after the date of consent provided by the Caller/Caller Agent).


Historically, there’s been a good source of permanently disconnected landlines, but not of wireless or VOIP numbers. As landline use decreases and mobile use skyrockets, this has become problematic for callers and calling agents trying to legally conduct business over the phone.

Large mobile and VOIP carriers were required to begin tracking permanent number disconnections beginning in July,2020, and smaller carriers were required to report permanent number disconnects in January 2021. The RND now tracks landlines, wireless numbers, and VOIP.

Companies who are not verifying numbers against the RND are at risk of violating the TCPA. The FCC does allow for Safe Harbor for companies who check a telephone number, receive a response that the number is callable, and an error is made.




Gain access to the Reassigned Numbers Database!

̲app Can Help You Comply With RND

MAIN LAW REQUIREMENT

Maine Passes Law Requiring Use of Reassigned Numbers Database

Since its introduction, the RND has been an important component of TCPA compliance, helping you avoid calling reassigned numbers and exposing yourself to significant fines and penalties. However, the stakes have gotten higher.

Individual states are beginning to strengthen the requirements for compliance. This leaves your company at risk at both the federal and state levels, as other states follow suit.

As of July 16th, 2024, Maine is the first state to require use of the RND, defined as ‘the database created and maintained by the Federal Communications Commission that identifies whether a telephone number has been reassigned.’


Maine also amended a section pertaining to telephone solicitation violations. It was already a violation to initiate a sales call to a consumer if that number has been on the state or national DNC registry for at least three months, but now specifies that it’s also a violation to fail to use the RND to verify that a number has not been reassigned. A telephone solicitor is not liable if they can show routine business practices for DNC and RND including:

  • Establishing and implementing written procedures for compliance.
  • Training of personnel and any associated entities on those procedures.
  • Recording and maintaining a list of Do Not Contact numbers by the solicitor or any associated entities calling on their behalf.
  • Using a process to prevent telemarketing to any number on any DNC registry (internal, state, or national), while using a version of the DNC registry not more than 31 days old, and maintaining records documenting this process.
  • Monitoring and enforcing compliance with all stipulations above.
  • Using the reassigned numbers database to verify that a consumer’s telephone number has not been reassigned prior to initiating a telephone sales call.

As states determine their own compliance stipulations, your company is at greater risk than ever before. Regulatory laws are constantly evolving, and your processes must evolve with them.




FAQS

Reassigned Number Database FAQs




  • A Caller Agent is any third-party contractor that a Caller engages to query the RND on their behalf.



  • No. Unlike state or national DNC lists, there is no RND list. The RND is queried with two pieces of information: the telephone number and a date. The date is either the date you received consent from the consumer, or the date that you are last reasonably sure the number belonged to the party you are attempting to reach.



      You will receive one of three responses:

  • Ԩ” –indicates the number HAS been permanently disconnected since the date provided and should not be called.
  • “N” –indicates the number HAS NOT been permanently disconnected since the date provided and is callable.
  • “No data” – this response could occur because consent was given PRIOR to the initial start date of July 2020, or because smaller carriers with less than 100k subscribers were not required to report permanent disconnects until January 2021.


Reassigned Number Database FAQs


̲app Can Help You Comply With RND

COMPLY WITH CONFIDENCE

̲app Can Help You Comply With RND

DNCSolution provides fully integrated access to the RND database as an optional, value-added service, and ̲app acts as a Caller Agent on our clients’ behalf. DNCSolution combined with the RND database ensures you maintain compliance with all federal regulations for calling landlines, wireless, and VOIP numbers.

Additionally, ̲app provides a full suite of enhanced services, such as full audit histories, reporting, data cleansing, and access to the list of known TCPA litigators, to go along with access to the RND.


Customers who add our Mobile Scoring Solution will be able to scrub mobile numbers against a database that does back to 2012, providing a much more robust verification method for numbers prior to the RND start date of July 27, 2020.


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