In order to avoid any non-filing fees or penalties, companies must make monthly filings for disconnected numbers and no disconnected numbers. The following article presents an overview of the Federal Communications Commission’s (FCC) Reassigned Numbers Database (RND or “the database”) and key impacts for companies.
Timeline of FCC Guidance
The FCC on December 18, 2018, released a Second Report and Order FCC-18-177A1 to address the actions needed to be taken to curb the wave of unwanted telephone calls a consumer may encounter due to a number not being directed or reassigned to the correct consumer. Due to unwanted calls being the largest complaint category, on December 13, 2018, the FCC created the RND, which reassigned number information from service providers that obtain numbers from the North American Numbering Plan Administrator (NANPA) or port in numbers from other service providers.
The RND allows a caller to determine if the number they want to call has been permanently disconnected or not, which will allow the avoidance of unwanted calls. With this database, the potential liability under the Telephone Consumer Protection Act (TCPA) will be reduced. The database was made available to paid subscribers on November 1, 2021.
On July 2, 2020, the FCC released Docket DA-20-706A1, stating that starting July 27, 2020, all voice service providers need to maintain records of the most recent date each number was permanently disconnected and let the number age a minimum of 45 days after disconnection before reassignment. The FCC released Docket DA-21-134A1, on February 8, 2021, requiring compliance reporting to be done within the database starting April 15, 2021 and recurring the fifteenth of every month thereafter, for all voice service providers. The requirements of the filing are to report disconnected numbers, through the tenth of the month, with a specific technical format and if no new disconnections happen during a month, the service provider must submit an empty file with no numbers listed to the RND.
Key Impacts
Per the FCC’s 47 CFR § 1.80(b)(10-11), failure to submit accurate data or missing filings by the due date will cause a $3,000 base forfeiture, $10,000 for each subsequent violation, and a larger penalty for anything thereafter. The FCC may remit or reduce any forfeiture based off a provider entering a consent decree to challenge the violation.
For reference, resources and information can be found on the reassigned.us website, which offers user guides and videos to help register1 and navigate through the database, as well as formatting and submission requirements.2 The RND submission process is under the “Submit” tab3 in the RND website, which also provides a list of frequently asked questions4 about the RND.
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- 1 “Service Provider/Service Provider Agent Registration Guide for the Reassigned Numbers Database,” https://www.reassigned.us/sites/default/files/resources/userguides/SP_SPA_Registration_User_Guide_1.pdf, March 10, 2022.
- 2 “Data Submit User Guide For the Reassigned Numbers Database,” https://www.reassigned.us/sites/default/files/resources/userguides/Submit%20User%20Guide_0.pdf, September 21, 2021.
- 3 “Submitting Data,” https://www.reassigned.us/submitting-data.
- 4 “Frequently Asked Questions,” https://www.reassigned.us/resources/faq.