Reassigned Numbers Database
RND / FCC Reassigned Numbers Database / reassigned number safe harbor
The Reassigned Numbers Database is an FCC database that tells a caller whether a phone number has been permanently disconnected since a given date, which means it may now belong to someone else. Querying it before calling on old consent is how a caller qualifies for the FCC's safe harbor for reaching a reassigned number.
The FCC created the database in an order released in December 2018, aimed at unwanted calls to people who inherited a number from its previous owner. Phone companies report to the database administrator each month the most recent date each of their numbers was permanently disconnected.
A number counts as permanently disconnected when the subscriber gives it up for good, or the provider takes it back from the subscriber. A number ported to another provider does not count.
A caller queries a number together with the date consent was obtained. The answer says whether the number has been permanently disconnected since that date. A number that has been disconnected since then may have a new owner who never agreed to anything.
The safe harbor in the FCC's rule is narrow. It covers a caller who had consent, queried the database, received a no, and still reached the wrong person because that no was an error. The caller bears the burden of proof and persuasion for all of it.
In practice
A heating and cooling company plans a round of automated maintenance reminder calls to customers who gave consent when they bought a system. Before the round goes out, it queries each number with the date that customer consented, and removes every number the database reports as disconnected since then. The company keeps the query records. If a stranger still receives a call because the database answered wrongly, those records are what the safe harbor asks it to produce.
Not the same as
- National Do Not Call Registry
- The Do Not Call Registry lists numbers whose owners have asked not to receive telemarketing calls. The Reassigned Numbers Database answers a different question: whether a number has been permanently disconnected since a date, so that consent given by its old owner may no longer apply.
Why it matters to you
Consent is given by a person, and a phone number can pass to someone else. A calling list built on consent collected years ago can have numbers that now reach strangers. Querying the database before each campaign, and keeping the results, is the route the FCC's rule offers to protection for those calls.
What to ask or check
- 01Does the calling platform query the Reassigned Numbers Database before a campaign, and with which consent date for each number?
- 02Where are the query results stored, and for how long?
- 03Which of these calls rely on prior express consent, and when was that consent collected?
What people get wrong
That checking the database protects any call made afterwards. The FCC's safe harbor covers a call that reached the wrong person because the database wrongly answered no, and the caller has to prove it.