July 24, 2021

Volume XI, Number 205

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BE PART OF THE SOLUTION!: Reassigned Number Database Beta Test Allows YOU to Help Determine the Future of the FCC’s Response to Recycled Number Problem

Well this is really interesting.

The long-awaited reassigned number database is coming to market soon. As part of the Administrator’s efforts to set up the database the FCC is inviting YOU to use an early version of the database (for free) to help the Commission set usage expectations and charges for the service when it becomes fully functional next year. Public notice here: Beta Test Public Notice

Although TCPAWorld readers need no reminders, the reassigned number database is needed to assist callers to know whether a consumer’s phone number has changed hands. Under current law a caller might (might) be held strictly liable under the TCPA if it calls a customer’s phone number that has changed hands without the caller’s knowledge. Because the TCPA is interpreted by some courts to require the consent of the current subscriber to the phone number—and the Florida Robocall bill has the same provision folks—a call to a wrong number makes the caller immediately liable as if the call had been made with no consent at all. That’s the bad news.

The good news is that the Commission created the reassigned number database to assist callers to determine whether a number has changed hand. In order to use the database the caller will need to have a “last good date” for each number it wishes to contact. It can then send that date, along with a number to be checked, to the Administrator of the database to determine whether the number has been permanently reassigned since the last good date. The Administrator will respond with a “yes” or a “no” informing callers of whether it is safe to call the number (in this context a “yes” is a bad thing—it means the number was reassigned since the last time the consumer was reached on the number.)

Using the reassigned number database should assist callers to prevent wrong number calls and cut down on TCPA risk. But callers will need to operationalize the scrub process needed to make proper use of the system and this BETA test invitation is a great way for callers to start getting with the program. It will help the Administrator and the Commission as well.

If you’re interested in being part of the beta test—and you are—more information is here https://www.reassigned.us/ or email support@reassigned.us for more information.

© Copyright 2021 Squire Patton Boggs (US) LLPNational Law Review, Volume XI, Number 167
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About this Author

Eric Troutman Class Action Attorney
Of Counsel

Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems.

Eric has built a national litigation practice based upon deep experience, rigorous...

213-689-6510
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