May 27, 2020

May 27, 2020

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May 26, 2020

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Recycled Number Relief Pushed to 2020: FCC Grants Further Extension on Reassigned Number Database Implementation

Quick update for anyone wondering what has become of the FCC’s reassigned number database.

Last December 2018 the FCC issued an Order creating a reassigned number database. The database would track the date of the last permanent disconnect of a cell phone number and enable potential callers to scrub against the database before attempting a call to a cell phone number. By using the database callers could avoid calls to wrong numbers—and the attendant risk of TCPA liability. And, in the event of an error in the database, callers would be granted a safeharbor if they otherwise properly scrubbed before attempting a call.

The database was originally expected to be rolled out in late 2019. But a series of delays have hampered its implementation. First, the FCC issued a public notice on two petitions seeking reconsideration of certain aspects of the order creating the database. Then, the North American Numbering Council’s (NANC) Numbering Administration Oversight Working Group—the outfit responsible for making technical recommendations needed to implement the database—sought a several month extension to complete its work. Whereas NANC’s recommendations were originally due June 13, 2019, the date was extended to September by order of the FCC issued June 12, 2019.

Well, last Thursday the Commission granted a further extension—this time to January 2020– to complete the technical analysis and an additional month to set a pricing structure. NANC reported that the work was more challenging than expected and needed vendors are, apparently, not cooperating. Notably, the NANC had sought an extension to April 2020 but the FCC was reluctant to wait that long.  As the FCC put it: “We are mindful of the need to establish an operational database as soon as possible and believe that this is sufficient time for the remaining work to be completed.”

The ruling can be found here: Reassigned Number Database Requirements

After the technical specifications and pricing elements are completed an Administrator will need to be chosen and the carriers will need to supply data to populate the database. Hence, it now looks like Summer, 2020 is now the earliest possible deployment for the database.

We’ll keep you posted.

© Copyright 2020 Squire Patton Boggs (US) LLP


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...