FCC Makes Changes to Reassigned Numbers Database to Improve Usefulness

The Federal Communications Commission last week issued supplemental guidance related to the Reassigned Numbers Database that updates the information included in the database in an attempt to make it more useful, after reports were surfacing that users were expressing concerns and were reluctant to use it.

The database, which went live on November 1, allows users to inquire whether a cell phone number has been disconnected or reassigned to someone else. Users can input a phone number and receive one of three answers — “yes” the number has been reassigned, “no” the number has not been reassigned, and “no data.” When inputting a phone number, users are required to also include a “date of consent” which is either the date the user obtained consent to call the number or the date in which the user was reasonably certain that the consumer could be reached at that number.

For users, the issue with the database was that the date of consent had to be after October 15 in order to guarantee a yes or no answer. Carriers were required to start maintaining reassigned data on January 27, 2021, but they did not have to begin reporting permanent disconnections to the database administrator until October 15. So that meant any number that was disconnected between January 27 and October 15 was resulting in a “no data” response when submitted to the database.

To correct the issue, the FCC has updated the database with disconnection data from all carriers going back to January 27, 2021. The FCC also provided this supplemental guidance:

  • The Reassigned Numbers Database will return a value of “yes” if the queried number is contained in the database and the date provided in the query is the same as or before the permanent disconnect date for that number in the Reassigned Numbers Database (i.e., the number has been permanently disconnected on or after the date that the caller enters into its query). Callers will not be eligible for the safe harbor described in section 64.1200(m) of the Commission’s rules for calling any number for which the Reassigned Numbers Database returns a value of “yes.
  • The Reassigned Numbers Database will return a value of “no” if the queried number is in the database and the date the caller provides in its query is after the permanent disconnect date contained in the database, or if the number is not in the database and the date the caller provides is on or after January 27, 2021, the date all service providers were required to maintain records of permanently disconnected numbers (i.e., the number has not been permanently disconnected after the date the caller enters into its query). Callers may be eligible for the safe harbor described in section 64.1200(m) of the Commission’s rules for calling a number for which the Reassigned Numbers Database returns a value of “no.”
  • The Reassigned Numbers Database will return a value of “no data” if the queried number and a permanent disconnect date are not contained in the database and the date provided in the query is before January 27, 2021, the date all service providers were required to maintain records of permanently disconnected numbers (i.e., the database does not contain either the date or number data queried by the caller). Callers will not be eligible for the safe harbor described in section 64.1200(m) of the Commission’s rules for calling any number for which the Reassigned Numbers Database returns a value of “no data.”

Explained the FCC: “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.”

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