The Federal Communications Commission officially launched the Reassigned Numbers Database (RND) on November 1, 2021. The RND is meant to help prevent consumers from receiving unwanted calls intended for someone who previously held their phone number. Callers are able to use the database to determine if a telephone number has been reassigned or not, making sure they are calling the correct person.
How the RND works is by returning one of three responses to callers to “explain whether the number has been reassigned (or more accurately, permanently disconnected) since the date provided”: “yes”, “no”, or “no data.” The Bureau issued guidelines for the RND in April 2020, but all service providers were not required to maintain records of the data until January 27, 2021. The Bureau also set October 15, 2021, as the date all service providers were required to begin reporting permanent disconnections to the RND Administrator on a monthly basis. On November 1, 2021, the database became fully operational for queries by paid subscribers.
When a caller queries the database, they input a phone number and a “date of consent,” which is either the date when the caller obtained consumer consent to call the number, or a date when the caller could be reasonably certain that the consumer could still be reached at the number. Due to how the Bureau initially set the relevant dates, callers reported receiving a high number of “no data” responses, with many of them appearing to be because of how the queries are defined in the database. This has caused concerns about the usefulness of the RND.
After two months of use, the Consumer and Governmental Affairs Bureau released a supplemental guideline that helps users understand the additional interpretation on when the database returns a “no” or “no data” response. All service providers were required, in their first report, to populate the database with initial data reaching back to at least January 27, 2021. Accordingly, the database now contains disconnection data from all service providers from that date. In order to provide callers with more certainty when they query the database, the FCC added this interpretation of when the database should return a “no” or “no data” response as applicable to this expanded set of disconnection data, as follows:
- 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 RND (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 RND 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 RND 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 RND returns a value of “no data.”
What this means at a high level, is that the meaning of the results as denoted 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.
The goal of the supplemental interpretation by the FCC is to maximize the usefulness of the RND by providing callers with the greatest amount of actionable information. Callers should keep a watch on further potential clarifications as the use of the RND grows.
If you have questions about how this impacts your partnership with Americollect, be sure to contact us and we will be more than happy to help.
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