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Compliance

Understanding the Reassigned Numbers Database

The FCC created the Reassigned Numbers Database to help businesses avoid calling numbers that have been reassigned to new individuals. Using the RND can provide safe harbor protection from certain TCPA claims.

Reassigned Numbers Database Compliance Guide

What is the Reassigned Numbers Database?

A centralized FCC resource to identify reassigned phone numbers

The FCC's Solution

The Reassigned Numbers Database is a centralized database established by the FCC in 2021 to track permanently disconnected phone numbers. By querying this database, businesses can determine if a number has been reassigned since they obtained consent.

Safe Harbor Protection

The RND provides safe harbor from certain TCPA liability for calls made to reassigned numbers. When you query the database, receive a 'No' response, and make the call promptly, you may be protected if the number turns out to have been reassigned.

Simple to Use

Using the RND is straightforward. Query the database with the phone number and the date you obtained consent. The database returns whether the number has been reassigned since that date. Consult legal counsel about how RND fits into your compliance program.

How the Reassigned Numbers Database Works

A simple query process designed to support your compliance efforts

1. Register for Access

Access the RND through the official portal at reassigned.us. Registration is required, and there are associated fees for queries. The registration process is straightforward and designed for businesses of all sizes.

2. Query Before Calling

Submit the phone number along with the date you obtained consent. The database checks if the number has been permanently disconnected and potentially reassigned since your consent date.

3. Review the Response

You receive one of three responses: 'Yes' means the number was reassigned since your consent date, 'No' means it was not reassigned, and 'No Data' means the database has no information about that number.

4. Act on the Results

If you receive a 'No' response and make your call within the timeframe covered by the database update, you may qualify for safe harbor protection. A 'Yes' or 'No Data' response means you should not call that number without new consent.

Questions About RND Integration?

Consult with qualified legal counsel about how the Reassigned Numbers Database fits into your compliance program. Drop Cowboy® account managers can share how our platform tools support your compliance efforts.

Safe Harbor Requirements

What you need to qualify for RND safe harbor protection

Prior Consent Required

Safe harbor only applies when you had prior express consent from the intended recipient at the phone number. The RND does not create consent. It helps verify that the person who gave consent still has that number.

Timely Database Query

Query the most recent update of the RND before making your call. The database is updated monthly. Safe harbor protection applies when you query the current version and act promptly on the results.

'No' Response Required

Safe harbor protection requires receiving a 'No' response indicating the number has not been reassigned since your consent date. 'Yes' and 'No Data' responses do not provide safe harbor protection.

Maintain Records

Keep detailed records of your database queries including dates, responses, and the actions you took. These records demonstrate your good-faith compliance efforts if ever questioned. Consult legal counsel about retention requirements.

Record-Keeping Best Practices

Documentation to support your compliance efforts

Query Date and Time

Record exactly when you queried the database. This timestamp demonstrates you used the most recent database version available and acted within an appropriate timeframe.

Phone Number Queried

Document which phone numbers you queried. Maintain a clear audit trail linking each number to its query result and the subsequent action you took.

Consent Date Submitted

Record the consent date you submitted with each query. This should match the date you obtained consent from the intended recipient for that phone number.

Response Received

Document the exact response you received: 'Yes', 'No', or 'No Data'. Include any reference numbers or confirmation codes provided by the database for your records.

Action Taken

Record what action you took based on the response. Did you proceed with the call? Did you remove the number from your list? This shows your compliance process in action.

Retention Period

Maintain these records for an appropriate period. Consult legal counsel about record retention requirements for your specific industry and use case.

Ready to Improve Your Compliance Program?

Drop Cowboy® provides platform tools to support your compliance efforts. Our team can explain how our features work alongside your RND processes.

Important Limitations

Understanding what the RND does and does not cover

Safe Harbor Scope

RND safe harbor protection only applies to reassigned number claims. It does not protect against other TCPA violations such as calling without consent, calling during quiet hours, or failing to honor opt-out requests.

'No Data' Responses

A 'No Data' response means the database has no information about whether that number was reassigned. This response does not provide safe harbor protection. Proceed with caution and consult legal counsel.

Database Update Frequency

The RND is updated monthly. Query results reflect data as of the most recent update. Plan your calling campaigns accordingly and consult legal counsel about appropriate timing between queries and calls.

Consult Legal Counsel

The RND is one tool in your compliance toolkit. Requirements vary by industry, call type, and jurisdiction. Always consult qualified legal counsel about how the RND fits into your specific compliance program.

Support Your Compliance Efforts with Drop Cowboy

Our platform includes tools designed to help you manage your calling campaigns responsibly. Quiet hours enforcement, opt-out management, and detailed audit logs support your overall compliance program.

Frequently asked questions

Everything you need to know about Drop Cowboy®

The Reassigned Numbers Database is an FCC-established centralized database that tracks permanently disconnected phone numbers. Businesses query it to check if a number has been reassigned since obtaining consent. The database launched in November 2021 to help reduce calls to wrong numbers. Consult legal counsel about integrating RND into your compliance program.
Access the RND through the official portal at reassigned.us. Register for an account, which requires business information and payment setup. Query fees apply per lookup. The registration process takes a few minutes. Consult legal counsel about how often to query based on your specific use case and calling patterns.
Safe harbor protection means that if you query the RND before calling, receive a 'No' response, and make the call promptly, you may be protected from TCPA liability if the number actually was reassigned. The protection is limited to reassigned number claims only. Consult legal counsel about safe harbor requirements for your situation.
Keep records of query date and time, phone number queried, consent date submitted, response received, and action taken. Store these records systematically for audit purposes. Record retention periods vary by industry and jurisdiction. Drop Cowboy® maintains detailed audit logs for platform activity. Consult legal counsel about your specific retention requirements.
'No Data' responses do not provide safe harbor protection. This response means the database has no information about that number. You should not assume the number has not been reassigned. Consult legal counsel about how to handle 'No Data' responses in your compliance program before proceeding with calls to those numbers.
The RND is updated monthly with new data from telephone carriers. When you query the database, you receive information current as of the most recent monthly update. Plan your query timing accordingly. Consult legal counsel about appropriate intervals between database queries and actual calling campaigns.
No. RND safe harbor only protects against claims related to calling reassigned numbers. It does not cover other TCPA requirements like obtaining proper consent, respecting quiet hours, or honoring opt-out requests. The RND is one tool in a comprehensive compliance program. Consult legal counsel about your complete TCPA obligations.
A 'Yes' response means the number was reassigned since your consent date. You should not call that number without obtaining new consent from the current number holder. Calling after a 'Yes' response would not qualify for safe harbor protection. Remove these numbers from your calling list or obtain fresh consent.
Drop Cowboy® provides platform tools to support your compliance efforts including automatic quiet hours enforcement, opt-out management, suppression lists, and detailed audit logs. These tools help you manage calling campaigns responsibly. Compliance is ultimately your responsibility. Consult legal counsel for guidance specific to your business.
The RND is not mandatory, but it provides a safe harbor that may protect against certain TCPA claims. Whether to use the RND depends on your specific business, call volume, and risk tolerance. Many businesses find the safe harbor protection valuable. Consult legal counsel about whether RND integration makes sense for your compliance program.

This content is for educational purposes only and does not constitute legal advice. The Reassigned Numbers Database and safe harbor provisions involve complex regulatory requirements. Compliance is ultimately your responsibility. We recommend consulting with qualified legal counsel regarding your specific compliance obligations and how the RND fits into your program.

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