FCC Issues Supplemental Guidance for Reassigned Numbers Database UsersJanuary 7, 2022
The guidance provides clarity on query responses in the FCC reassigned numbers database and when the TCPA safe harbor applies.
01/06/2022 3:30 P.M.
4.5 minute read
The Federal Communications Commission’s Reassigned Numbers Database became fully operational on Nov. 1, 2021, and the commission has now released supplemental guidance to improve the utility of the database and enhance callers’ ability to avoid making unwanted calls to consumers.
Now that the database, which had been in development since 2018, is live, callers can check it to “ensure they reach consumers that expect their calls and avoid calling consumers with reassigned numbers who may not wish to receive the call,” according to the FCC’s supplemental guidance.
The reassigned numbers database helps callers by returning one of three responses to explain whether the number has been reassigned (or, more accurately, permanently disconnected) since the date provided: “yes,” “no,” or “no data.”
Callers using the database have reported receiving a high number of “no data” responses to their queries, and many of the “no data” responses appear to be a result of how the queries are defined in the database, according to the FCC.
Voice service providers were required to maintain records of consumers’ phone numbers by Jan. 27, 2021, after the FCC’s Consumer and Governmental Affairs Bureau issued guidelines for using the database in April 2020.
Voice service providers were required to begin reporting permanent disconnections to the reassigned numbers database administrator by Oct. 15, 2021, and on a monthly basis thereafter.
Now that the database has been active for a few months, the FCC has data to evaluate users’ experiences—especially the call query responses.
“When querying the database, callers input a phone number and a ‘date of consent,’ which is either the date when the caller obtained consent from the consumer to call the number or a date when the caller could be reasonably certain that the consumer could still be reached at that number,” according to the FCC.
However, because of the break in time between when voice service providers had to start maintaining data on disconnects (January 2021) and when they officially had to report the data (October 2021)—the database has started to return a “no data” response to callers even though the database contains actionable information regarding whether the number has in fact been disconnected.
The “no data” responses fail to indicate if a phone number has reassigned to a different consumer or disconnected, and are not as useful as a “yes” or “no” response—causing a reluctance among subscribers to use the database.
To remedy the issue, the FCC has additional interpretation on when the database should return a “no” or “no data” response:
“At a high level, the meaning of the results, as prescribed by the Reassigned Numbers Order, remains unchanged: ‘yes’ means the…